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…
The Canada Revenue Agency ("CRA") has submitted its written responses to TEI's December 2023 CRA-TEI liaison meeting questions regarding income taxes.
Read the responses here.
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 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 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…
Members of TEI's Canadian Commodity Tax Committee met virtually with the British Columbia Ministry of Finance on June 24, 2024. In addition to requests for updates on questions from past liaison…
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…