TEI Comments on Canadian Draft Income Tax Legislative Proposals
On September 10, 2018, TEI submitted comments to the Department of Finance Canada concerning two of the draft income tax legislative proposals that were released for public consultation on July 27, 2018.
TEI Comments on Scope of Revisions to OECD Transfer Pricing Guidelines
On June 19, TEI submitted comments to the OECD regarding the scope of future revisions to Chapters IV and VII of the OECD’s transfer pricing guidelines. TEI’s comments focused on the practical aspects of any future guidance.
TEI Comments on Proposed Change to Canada’s Foreign Affiliate Reporting Requirements
On May 1, 2018, TEI submitted comments to the Canadian Department of Finance concerning the government’s proposed change to the filing deadline for Form T1134, Information Return Relating to Controlled and Not-Controlled Foreign Affiliates. TEI’s comments, reprinted below, were prepared by a cross-industry working group of Canadian Income Tax Committee members under the leadership of Sue Wooles.
TEI Comments on Corporate Tax Reform Implementation Issues and Guidance Priorities
In April 2018, the Institute's legal staff worked with a diverse, cross-industry group of senior Federal Tax Committee and Tax Reform Task Force members to distill a responsive list of corporate tax guidance priorities in the wake of comprehensive tax reform.
TEI Comments on the European Commission’s Digital Economy Tax Proposals
On May 15, TEI submitted comments regarding the European Commission’s proposals to define the concept of a “significant digital presence” for corporate income tax purposes and impose an interim digital services tax.
TEI Files Comments on Canada’s proposed Greenhouse Gas Pollution Pricing Act and Draft Fuel Charge Regulation
On February 28, 2018, TEI filed comments on the proposed Greenhouse Gas Pollution Pricing Act and Draft Fuel Charge Regulation released by the Department of Finance and Ministry of Environment and Climate Change on January 15, 2018.
TEI Submits Comments to the FASB on the ASC 740 Treatment of the New BEAT and GILTI Regimes
TEI, through its Financial Reporting Committee and under the leadership of chair Stephen Dunphy (Silicon Valley Chapter), filed comprehensive comments with the FASB on the financial statement treatment under ASC 740 of the new BEAT (Base Erosion Anti-Abuse Tax) and the GILTI (Global Intangible Low-Taxed Income) tax regime. The BEAT and GILTI were enacted as part of tax reform legislation signed into law on December 22, 2017.
TEI Comments on European Commission Digital Economy Survey
On January 2, TEI submitted responses to the European Commission’s survey regarding “fair taxation of the digital economy,” disagreeing with the Commission’s proposed alternatives to taxing digital commerce.
TEI Alerts Congress to Unintended Consequences of Retaining Corporate AMT in Tax Reform
During the first week of December 2017, a cross-industry group of senior Tax Reform Task Force members coalesced to alert the Congress to several likely unintended consequences of retaining the corporate alternative minimum tax under H.R. 1, the Tax Cuts and Jobs Act.
TEI Comments on Taxation of Offshore Indirect Transfer
On October 19, TEI submitted comments to the Platform for Collaboration on Tax regarding the Platform’s draft toolkit on the taxation of offshore indirect transfers.