Comment Letters

TEI Comments on OECD Request Regarding the Digitalization of the Economy

On October 12, TEI submitted comments to the OECD regarding their request for input on the tax challenges of the digitalization of the economy, including an interim report to be submitted to the G20 finance ministers.

TEI Comments on OECD Discussion Draft Regarding Revised Profit Split Guidance

On September 8, TEI filed comments with the OECD regarding its public discussion draft on revised guidance on the use of profit splits.

TEI Submits Comments to the IRS in Response to Notice 2017-36 on the Final Documentation Regulations Under Section 385

In August 2017, a diverse working group comprising members of the Federal Tax Committee, U.S. International Committee, and Tax Reform Task Force reconvened to produce responsive comments to Notice 2017-36, One-Year Delay in the Application of § 1.385-2, on the final debt documentation regulations under section 385.

TEI Submits Comments to the IRS in Response to Notice 2017-38 on the Final and Temporary Section 385 Regulations

In July 2017, a diverse working group comprising members of the Federal Tax Committee, U.S. International Committee, and Tax Reform Task Force coalesced to produce responsive comments to Notice 2017-38, Implementation of Executive Order 13789 (Identifying and Reducing Tax Regulatory Burdens), on the final and temporary regulations under section 385.

TEI Submits Comments on Proposed Changes to the Canada Revenue Agency’s Voluntary Disclosures Program

In July 2017, a diverse working group comprising members of the Canadian Income Tax Committee and Canadian Commodity Tax Committee coalesced to produce responsive comments to the Canada Revenue Agency’s proposed changes to the Voluntary Disclosures Program.

TEI Comments on Order Governing Transition to Spain’s Immediate Supply of Information System

On July 28, 2017, TEI filed a letter with the Spanish Tax Agency addressing Ministerial Order HFP/417/2017 of 12 May 2017, which contains the legal and technical requirements for maintaining VAT registers in the Spanish Tax Agency’s Immediate Supply of Information System (SII).

TEI Files Comments on Canada’s Technical Paper Regarding Federal Carbon Pricing Backstop

On June 30, 2017, TEI filed comments on the Technical Paper on the Federal Carbon Pricing Backstop released by the Canada Department of Finance. TEI’s comments were prepared under the aegis of TEI’s Canadian Commodity Tax Committee, whose chair is David Card.

TEI Comments on OECD Hard-to-Value-Intangibles Draft

On June 29, TEI submitted comments to the OECD on its public discussion draft regarding Implementation Guidance on Hard-to-Value Intangibles.

TEI Urges Washington Legislature to Enact Legislation Establishing an Independent Tax Court

On June 16, 2017 TEI submitted a letter to Senator Braun and Representative Jinkins of the Washington Legislature urging the legislature to enact Senate Bill 5866, 2nd Substitute, which would establish an independent tribunal to hear appeals of tax assessments and other matters administered by the Washington Department of Revenue.

TEI Responds to the European Commission’s Public Consultation Regarding the Definitive VAT System for Business to Business Intra-EU Transactions on Goods

TEI Responds to the European Commission’s Public Consultation Regarding the Definitive VAT System for Business to Business Intra-EU Transactions on Goods.
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