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…
On October 2, 2024, TEI submitted supplemental comments on Notice 2023-63 and section 174, with a particular focus on rules related to software development for future proposed regulations. The…
On September 11, 2024, TEI submitted comments to the Canadian Department of Finance regarding proposed amendments to the bare trust reporting rules under section 150 of the Income Tax Act. TEI's…
On September 10, 2024, TEI submitted comments to the European Commission regarding its review of its anti-tax avoidance directive, or "ATAD." TEI's comments focused primarily on whether the ATAD is…
On August 28, 2024, TEI submitted comments regarding the European Commission's draft implementing regulation for the Commission's public country-by-country ("CbC") reporting directive. TEI's comments…
On August 19, 2024, TEI submitted comments regarding the OECD's Draft User Guide for the GloBE Information Return XML Schema. TEI's comments emphasized the need for information return exchange…
On July 24, 2024, TEI submitted comments on Notice 2023-63 and section 174, with a particular focus on rules related to software development for future proposed regulations. TEI requested rules for…
On July 10, 2024, TEI submitted comments to the Ministry of Finance of Singapore regarding its bill to implement a multinational enterprise top-up tax and a domestic top-up tax as part of Singapore's…
On June 11, 2024, TEI submitted comments on the proposed regulations on the stock repurchase excise tax. TEI requested clarification on the method for electing to apply the proposed regulations…
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…
On May 29th, 2024, TEI filed comments with Canadian Minister of Finance Chrystia Freeland regarding Budget 2024's proposed expanded Canada Revenue Agency audit powers. TEI's comments focused on the…
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…