Comment Letters

On September 18, TEI submitted comments to the Treasury and IRS regarding proposed regulations under section 951A, better known as “GILTI”, commending the Government on the proposed GILTI high-tax exception and recommending certain changes to the exception consistent with sound tax policy.

Summary Sentence/Magazine Intro (1-2 sentences; abbreviate TEI; include committee and contributor recognition if needed): On August 12, TEI submitted comments to the Treasury and IRS regarding proposed regulations under section 59A, better known as the “BEAT”, recommending an alternative method to calculate a taxpayer’s BEAT liability.

On June 26, 2019, TEI filed a letter with the British Columbia's Select Standing Committee on Finance and Government Services proposing changes to British Columbia's provincial sales tax.

TEI submits comments to the FASB concerning proposed changes to ASC 740.

On May 29, 2019, TEI submitted a letter to the Canadian Department of Finance welcoming the government’s intention to expand the joint venture election under Section 273 of the Excise Tax Act.

On May 6th, TEI submitted comments to the Internal Revenue Service and U.S. Department of the Treasury regarding proposed regulations on the new section 250 deductions for foreign-derived intangible income and global intangible low-taxed income.

On March 4th, TEI submitted comments to the OECD regarding its public consultation document entitled Addressing the Tax Challenges of the Digitalisation of the Economy. TEI will also participate in in the upcoming public consultation on March 13-14 in Paris.

On February 26, 2019, TEI submitted responsive comments and recommendations to the Internal Revenue Service concerning the proposed regulations under section 163(j) of the Internal Revenue Code (REG-106089-18). TEI’s comments, which are reprinted below, were developed by a cross-industry working group of Tax Reform Task Force and Federal Tax Committee members under the stewardship of Watson M. McLeish, tax counsel for the Institute.

On February 22, 2019, TEI submitted responsive comments and recommendations to the Internal Revenue Service concerning the interim guidance provided for taxpayers in Notice 2018-99. TEI’s comments, which are reprinted below, were developed by a cross-industry working group of Tax Reform Task Force and Federal Tax Committee members under the leadership of Katherine C. Castillo and Julia Lagun. Watson M. McLeish, tax counsel for the Institute, coordinated the preparation of TEI’s comments.

On February 19th, TEI submitted comments to the Treasury and IRS regarding proposed regulations providing guidance under section 59A regarding the base erosion and anti-abuse tax.