U.S. International Tax

The U.S. International Tax Committee works on educational and advocacy efforts regarding the U.S. taxation of international business operations.

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 June 10, 2024, TEI sent a letter to the Brazilian tax authorities recommending Brazil adopt a cooperative compliance program with taxpayers. TEI noted the advantages of such a program include providing tax authorities with transparency and taxpayers with certainty, improving the risk assessment process, and assist the Brazilian tax authorities in implementing Brazil's new transfer pricing legislation, among other things. TEI's letter was prepared under the aegis of its U.S. International Tax Committee. Benjamin R.

On March 31, 2024, TEI submitted comments to the Internal Revenue Service (the "Service") regarding foreign tax redeterminations ("FTRs") under section 905(c). The post-TCJA final regulations resulted in a significant increase in the compliance burden on taxpayers with FTRs. TEI's letter recommended several methods to reduce this compliance burden as well as the administrative burden on the Service when auditing FTRs. TEI's comments were prepared under the aegis of its U.S. International Tax Committee, whose Chair is Ag Samoc. 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 February 12, 2024, TEI submitted comments regarding REG-132422-17 addressing recognition and deferral of section 987 gain or loss. TEI's comments included several simplifying recommendations to ease the compliance burden on taxpayers, a request to defer the effective date of any final regulations, and how to address suspended losses. Benjamin R. Shreck, TEI Tax Counsel, coordinated the preparation of TEI's comments.

Read the comments here.

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.

Download the letter.

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