TEI Files Comments regarding Proposed Regulations addressing the Foreign Tax Credit
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.
TEI Files Comments regarding the OECD Secretariat’s “Unified Approach” to Pillar One
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.
TEI Files Comments on the Proposed GILTI High-Tax Exception
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.
TEI Files Supplemental Comments on Proposed BEAT Regulations
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.
TEI Submits Comments regarding FDII and GILTI Deductions
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.
TEI Submits Comments to the OECD regarding Digitalization of the Economy Consultation
On March 4th, TEI submitted comments to the OECD regarding its public consultation document entitled Addressing the Tax Challenges of the Digitalisation of the Economy. TEI will also participate in in the upcoming public consultation on March 13-14 in Paris.
TEI Submits Comments to the Treasury and IRS regarding Proposed BEAT Regulations
On February 19th, TEI submitted comments to the Treasury and IRS regarding proposed regulations providing guidance under section 59A regarding the base erosion and anti-abuse tax.