Comment Letters

TEI Supports the ABA's Model State Tax Tribunal Statute

On February 14, 2012, TEI submitted a letter to the American Bar Association expressing the Institute's strong support for the ABA's Model State Administrative Tax Tribunal Act. TEI has long supported independent state tax tribunals, and the ABA Model Act is consistent with the Institute's Policy Statement on Independent State Tax Tribunals.

The comments were prepared under the aegis of TEI's State and Local Tax Committee, whose chair is Howard E. Grindle. Daniel B. De Jong of the Institute's legal staff coordinated the development of the Institute's comments.

TEI Supports Legislation Establishing Independent Tax Court in Alabama

On February 14, 2012, TEI submitted a letter in support of legislation in Alabama (HB 105) that would establish a pre-payment, independent tribunal to hear appeals of tax assessments and other matters administered by the Alabama Department of Revenue, as well as certain taxes levied by or on behalf of counties and municipalities.

TEI Supports Federal Conformity Legislation in Wisconsin

On October 5, 2011, Tax Executives Institute submitted the following comments to key leaders of the Wisconsin legislature, endorsing legislation to conform Wisconsin's tax law to federal provisions relating to the income tax exclusion for employer-provided health care insurance, which were changed by the 2010 health care reform law.

TEI Supports Passage of Mobile Workforce Legislation

On July 22, 2011, Tax Executives Institute submitted the following comments to the House Committee on the Judiciary and its Subcommittee on Courts, Commercial and Administrative Law, recommending the enactment of H.R. 1864, the Mobile Workforce State Income Tax Simplification Act of 2011. TEI endorses federal legislation that would create a uniform standard for the state taxation of income earned by employees who travel for work, and the related withholding obligations of their employers.

TEI Comments on the Future of the VAT

On May 31, 2011, TEI submitted comments to the European Commission on a Green Paper consultation titled "On the future of VAT: Towards a simpler, more robust and efficient VAT system." The comments were prepared by TEI's European Indirect Tax Committee, whose 2011-2012 Chair is Siegert Slagman. Jeffery P. Rasmussen of the Institute's legal staff assisted with the comments.

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TEI Supports Harmonized Sales Tax in British Columbia

On April 29, 2011, TEI submitted a letter opposing a referendum to rescind British Columbia's Harmonized Sales Tax and restore the Provincial Sales Tax. TEI's letter summarizes the Institute's general support for the HST and the implications if it were to be repealed. The Institute's comments were prepared under the aegis of its Canadian Commodity Tax Committee, whose chair is Kim N. Berjian.

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TEI Supports Creation of Independent Tax Court in Alabama

On April 12, 2011, TEI filed a letter urging the Alabama legislature to pass bill establishing a pre-payment, independent tax appeals tribunal but raising concerns with the legislation's proposed "substantial understatement" penalty. TEI's comments were prepared under the aegis of its State and Local Tax Committee, whose chair is Linda Dickens. Daniel B. De Jong, TEI Tax Counsel, serves as legal staff liaison to the committee and coordinated the preparation of the letter.

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TEI Supports OECD VAT/GST Neutrality Guidelines

On March 30, 2011, TEI sent a letter to the OECD affirming direction of OECD's VAT/GST neutrality guidelines. TEI's comments were prepared by the Institute's European Indirect Tax Committee, whose chair is Jean-Daniel Rouvinez. Jeffery P. Rasmussen of the Institute's legal staff assisted with the comments.

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TEI Urges Changes to Canada Regulation on Restricted Input Tax Credits

On March 7, 2011, TEI submitted a letter to Finance Canada and Canada Revenue Agency recommending amendments to the Harmonized Value-added Tax System regulations to make restricted input tax credit (RITC) reporting administrable. The letter follows up on TEI's December 2010 liaison meetings with Canada Revenue Agency and the Department of Finance, where TEI representatives raised the timing for reporting and applying the rules relating to RITCs. TEI maintains that reporting RITCs pursuant to the timeframes required in Harmonized Value-added Tax System Regulations, No.

TEI Files Amicus Letter in California's California Taxpayers' Association Penalty Litigation

On February 24, 2011, TEI filed an amicus letter with the California Supreme Court urging the Court to grant the pending Petition for Review filed by the California Taxpayers's Association in Supreme Court Case No. S189996.

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