U.S. International Tax

On October 16, 2020, TEI submitted comments to the Large Business & International Division of the IRS urging the division to retain Rev. Proc. 94-69 and extend it to all taxpayers subject to the Large Coordinated Case Program.

On September 11, TEI submitted comments to the IRS regarding proposed changes to Form 1065 relating to international item reporting.

On February 27–28, 2020, a delegation of Executive Committee members, standing committee leaders, and Institute staff assembled in Washington, D.C., for TEI’s annual liaison meetings with the Internal Revenue Service and U.S. Department of the Treasury.

On February 18, TEI submitted comments to the IRS and U.S. Treasury Department regarding proposed regulations related to the U.S. foreign tax credit. TEI’s comments primarily addressed the administrative burden the proposed regulations would impose on claiming a foreign tax credit due to a foreign tax redetermination under section 905(c), as well as issues related to “stewardship” expenses.

On December 2, TEI filed comments responding to the OECD’s public consultation document entitled Global Anti-Base Erosion Proposal (“GloBE”) – Pillar Two, focusing on the need for states to withdraw unilateral measures, a strong binding dispute resolution mechanism, and clear ordering rules, among other things.

On November 11, TEI submitted comments to the OECD Secretariat regarding its proposed “unified approach” to “Pillar One” of the tax challenges of the digitalization of the economy. TEI’s comments focused on the need for (i) the withdrawal of unilateral measures after a multilateral agreement, (ii) a multilateral dispute resolution mechanism; and (iii) reliance on taxpayer consolidated financial statements for purposes of the approach, among other subjects.

On September 18, TEI submitted comments to the Treasury and IRS regarding proposed regulations under section 951A, better known as “GILTI”, commending the Government on the proposed GILTI high-tax exception and recommending certain changes to the exception consistent with sound tax policy.

Summary Sentence/Magazine Intro (1-2 sentences; abbreviate TEI; include committee and contributor recognition if needed): On August 12, TEI submitted comments to the Treasury and IRS regarding proposed regulations under section 59A, better known as the “BEAT”, recommending an alternative method to calculate a taxpayer’s BEAT liability.

On May 1–2, 2019, a delegation of Executive Committee and Tax Reform Task Force members assembled in Washington, D.C., for the Institute’s first set of congressional liaison meetings since the late 1990s.

On May 6th, TEI submitted comments to the Internal Revenue Service and U.S. Department of the Treasury regarding proposed regulations on the new section 250 deductions for foreign-derived intangible income and global intangible low-taxed income.