The Federal Income Tax Committee is responsible for TEI’s educational and advocacy efforts for U.S. federal income tax matters.
TEI Submits Comments on Notice 2023-2 and the Stock Repurchase Excise Tax
On March 20, 2023, TEI submitted comments in response to a request for comments in Notice 2023-2, which provided guidance on the stock repurchase excise tax. The comments requested carve-outs from the tax for redemptions of non-participating, non-convertible preferred stock and addressed the funding rule and related per se rule that were introduced in the notice. In particular, the comments requested either the removal of the rules from future guidance or a significant narrowing of the rules as they are overbroad and go beyond the literal language and purposes of the statute.
TEI Comments on IRS Notice 2023-7 Regarding the New Corporate AMT
On March 20, 2023, TEI submitted a letter to the Internal Revenue Service commenting on Notice 2023-7, which provides initial guidance on the new corporate alternative minimum tax (CAMT) imposed by the Inflation Reduction Act of 2022. TEI's comments included the need for transition rules and penalty relief, adjustments to the determination of adjusted financial statement income (aka AFSI), among other things. TEI's comments were prepared under the aegis of the Institute's Tax Reform Task Force, whose Chair is Jason Weinstein.
TEI Requests Guidance on the Capitalization of R&E Expenditures under Section 174
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 of 2017, effective for tax years beginning after December 31, 2021. TEI’s comments were developed by members of several TEI standing committees under the aegis of TEI’s Federal Tax Committee, whose chair is Julia Lagun, and the effort was led by Betty Mak, a vice chair of the committee.
TEI Submits Comments on the Capitalization of R&E Expenditures under Section 174
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 2022 calendar year to postpone, if not repeal, the mandatory capitalization of expenditures under section 174. TEI’s comments were developed by members of several TEI standing committees under the aegis of TEI’s Federal Tax Committee, whose chair is Julia Lagun, and the effort was led by Betty Mak, a vice chair of the committee.
TEI Submits Comments on Proposed Changes to Schedule UTP
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 deliberative manner and urged the IRS to put an indefinite hold on the proposed changes and engage in a meaningful collaboration with stakeholders to identify reasonable alternatives.
TEI Submits Comments on the IRS Form Being Developed to Standardize Rev. Proc. 94-69 Disclosures
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 agents will have consistent guidelines around what constitutes adequate disclosure. TEI’s comments expressed fundamental concerns surrounding the proposed consequences of a deemed failure to provide adequate disclosures and provided a number of detailed suggestions intended to eliminate confusion and uncertainty when describing adjustments in the form.
TEI Comments on the Build Back Better Act’s Corporate and International Tax Reform Proposals
On December 9, 2021, TEI issued a compilation of substantive comments and recommendations concerning select corporate and international tax reform provisions in H.R. 5376, the Build Back Better Act, as passed by the House of Representatives on November 19, 2021. This submission represents the culmination of several months’ worth of consultation with members of TEI's Tax Reform Task Force and other standing committees, who contributed an array of perspectives and concerns from across the industry spectrum.
TEI Issues Guideposts for Tax Policy in the 117th Congress
On May 11, 2021, TEI officially weighed into the brewing tax reform debate in Washington, D.C., through the issuance of its new Guideposts for Tax Policy. The guideposts are intended to highlight a series of high-priority, broadly applicable principles of sound tax policy to inform the current deliberations in the 117th Congress and Biden administration. They are also intended to lay a solid, principles-based foundation to support TEI’s substantive, issue-focused advocacy activities in the weeks and months ahead. TEI encourages policymakers to adopt these guideposts