Interest allocation: the dog days of summer Bret Wells What a difference a summer makes! Earlier this year, many had high hopes that the United States would finally correct the most significant tax mistake facing U.S. multinationals, namely the current method for allocating and apportioning interest expense among U.S. and foreign assets. From its inception, […]
Quebec capital tax: November 21, 2003 On November 21, 2003, the Montreal Chapter of Tax Executives Institute submitted the following letter to Minister of Finance Yves Seguin to express concern over a proposed delay in the reduction of the Quebec capital tax burden. The letter was prepared by the Montreal Chapter, whose president is Jean-Pierre […]
Interest on federal tax deficiencies and overpayments James V. Heffernan Interest on Federal Tax Deficiencies and Overpayments Introduction Like many areas of our federal income tax laws, the computation of interest on tax deficiencies (1) and overpayments has become increasingly complex over the years. Fortunately, some of this increasing complexity has been offset by the […]
The consequences of electing out of Subchapter K Bradley M. Seltzer I. Introduction Subchapter K of the Code(1*) provides specific rules applicable to the tax treatment of partnerships and partners. The various rules of Subchapter K reflect two disparate theories regarding the fundamental nature of a partnership and its relationship to its partners — the […]
Provincial sales tax and GST harmonization – goods and services tax – Tax Executives Institute On October 11, 1994, Tax Executives Institute submitted letters to the ministers of finance for all Provinces in Canada, which urged the ministers to continue meeting with representatives of the federal government in the ongoing dialogue concerning alternative taxes to […]
Executive summary of ‘Value-Added Taxes: A Comparative Analysis.’ Gareth E. Glaser Editor’s Note: The following article summarizes Value-Added Taxes: A Comparative Analysis, a book by the Consumption Tax Committee of Tax Executives Institute. The book, which was published by the I 1992, may be purchased for $30 (plus applicable sales tax) by writing to Tax […]
Are U.S. tax incentives for corporate R&D likely to motivate American firms to perform research abroad? – research and development B. Anthony Billings Current U.S. tax policy toward research and development (R&D) is based on the notion that the United States is the dominant competitor in the world for technology-intensive products. (1) While there is […]
Amortization of intangibles under sections 167 and 197 – comments submitted Sept 29, 1997 by Tax Executives Institute to the IRS regarding Internal Revenue Code sections 167 and 197 On September 29, 1997, Tax Executives Institute submitted the following comments to the Internal Revenue Service on proposed regulations under sections 167 and 197 of the […]
Study of taxpayer confidentiality October 21, 1999 On October 21, 1999, Tax Executives Institute filed the following comments with the staff of the Joint Committee on Taxation and the Department of the Treasury relating to the confidentiality of tax returns and tax return information. The comments were prepared under the aegis of TEI’s IRS Administrative […]
Comments on EU place of supply of services rules: June 30, 2003 On June 30, 2003, TEI President Drew Glennie sent the following letter to John Bain of the European Commission on the VAT place of supply of services rules. The comments were prepared under the aegis of TEI’s International Tax Committee, with guidance from […]