The efforts of TEI members around the world are impressive ... and appreciated.

AuthorAlicandri, Vincent
PositionTax Executives Institute

The range of TEI's advocacy work is shown by the contents of this issue. The work of the Institute's technical committees has been as varied as the interests and obligations of our members and the companies they work for. "Example A" is the work of a multinational group of TEI members--from Canada, the United States, and several European countries--who worked together (under the joint aegis of the European Direct Tax Committee, the International Tax Committee, and the Canadian Income Tax Committee) to develop a lengthy submission to the Organisation for Economic Co-Operation and Development on the transfer pricing implications of business restructurings. This project illustrates the challenges and opportunities inherent in TEI's consensus model of decision-making, inasmuch as the weight assigned to various issues by the members of the working group was not uniform. Nevertheless, the good faith, pragmatism, and commitment to effectively communicating the Institute's concerns by everyone in the group contributed positively to the final result.

It is often said that the proof of the pudding is in the eating, and by analogy, the effectiveness of TEI's advocacy efforts properly lies in the reception our submissions receive from government authorities. It is too early to tell whether the OECD will modify its rules to take our comments into account, but our work sufficiently impressed the OECD to garner the Institute an invitation to participate in a June meeting in Paris on the business restructuring projects. My thanks to everyone who became involved in the project--especially Committee Chairs Johann Mueller, Brian Ugai, and Rod Bergen, as well as Tax Counsel Jeff Rasmussen. By their example, they have enhanced TEI's effectiveness; by daring to make a difference, they have.

The latest OECD initiative was only one of the projects that drawing TEI's attention this spring. Thus, our State and Local Tax Committee weighed in with the U.S. Supreme Court, filing a formal "friend of the Court" brief relating to the constitutionality of Alabama's so-called add-back rule. The Canadian Commodity Tax Committee prepared a short letter to the government of Ontario on the merits of harmonizing the province's retail sales tax with the federal goods and services tax. Our International Tax Committee addressed important projects relating to cost sharing and contract manufacturing. And our Canadian Income Tax Committee took advantage of an invitation from the...

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