Tax Reform Task Force

On October 7, 2024, TEI submitted comments to the Internal Revenue Service and U.S. Department of the Treasury regarding proposed regulations addressing dual consolidated losses ("DCL") and new disregarded payment loss rules. TEI's comments focused on the interaction of the DCL rules and the OECD Pillar Two regimes, "triggering events" under the DCL rules, and the newly created DPL regime, among other things. TEI's comments were prepared under the aegis of its Tax Reform Task Force, whose Chair is Andreia Verissimo. Benjamin R.

On February 9, 2024, TEI submitted comments to the Internal Revenue Service and U.S. Department of the Treasury regarding Notice 2023-80 (the "Notice"). The Notice provides interim guidance addressing the application of the foreign tax credit and dual consolidated loss ("DCL") rules to certain types of taxes described in the OECD Pillar Two Global Anti-Base Erosion ("GloBE") Model Rules.

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.

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.

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.

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.

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