Submissions

On February 13, 2023, TEI filed comments with the Canada Revenue Agency regarding Draft Form RC312 - Reportable Transaction and Notifiable Transaction Information Return. TEI's comments primarily…
On February 3, 2023, TEI provided comments to the Organisation for Economic Co-operation and Development ("OECD") regarding its public consultation on GloBE tax certainty under the OECD's two pillar…
On February 3, 2023, TEI submitted comments to the Organisation for Economic Co-operation and Development ("OECD") regarding the GloBE Information Return under Pillar Two of the OECD's project on the…
On January 31, 2023, TEI filed comments and recommendations with the Canadian Department of Finance regarding proposed excessive interest and financing expense limitation (EIFEL) legislation. The…
On January 25, 2023, TEI submitted comments to the Organisation for Economic Co-operation and Development ("OECD") regarding the OECD's public consultation on the design elements of Pillar One,…
On December 9, 2022, TEI submitted written comments to Congress regarding the changes to section 174 under the Tax Cuts and Jobs Act of 2017. The comments urged Congress to act before the end of the…
On November 30, 2022, TEI submitted written comments to the U.S. Department of the Treasury and Internal Revenue Service requesting guidance on changes to section 174 under the Tax Cuts and Jobs Act…
On November 17, 2022, TEI submitted comments to the IRS on proposed changes to Schedule UTP. The comments identified a variety of critical policy issues that must be evaluated in a thoughtful and…
On October 18, 2022, TEI submitted written comments to the U.S. Department of the Treasury and Internal Revenue Service regarding the Inflation Reduction Act’s new corporate alternative minimum tax…
On July 21, 2022, TEI submitted preliminary comments to the Department of Finance concerning the Government of Canada’s proposal to implement Pillar Two of the OECD/G20 Inclusive Framework on Base…
On June 30, 2022, TEI applied for leave to intervene (as amicus curiae) in Deans Knight Income Corporation v. Her Majesty the Queen, a case in which the taxpayer was recently granted leave to appeal…
On June 1, 2022, TEI submitted comments on draft IRS Form 15307, which the IRS is developing to standardize the process for making Rev. Proc. 94-69 disclosures so eligible taxpayers and revenue…
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