TEI Responses to the European Commission's Public Consultation Regarding the Evaluation of Invoicing Rules.

• Position: Tax Executives Institute

On September 20 and 24, 2018, TEI filed submissions responding to the European Commission's Public Consultation regarding the evaluation of invoicing rules TEI's comments were prepared under the aegis of TEI's European Indirect Tax Committee, whose Chair is Gorka Echevarria, with the assistance of Mr. Echevarria and Werner Engelen, the Committee's Vice Chair and the following members of the EITC: Anna Ogenblad, Catherine O'Neill, Lide Mendibil, Bert Rosenberg, Srdjan Timotic, and Karl-Heinz Haydl. TEI Tax Counsel, Pilar Mata, coordinated the preparation of the submission.

We write to urge [state agency] to automatically waive penalties for failure to file corporate tax returns due on October 15, 2018 if a taxpayer files such returns no later than November 15, 2018. The due date for filing extended federal corporate tax returns was changed from September 15 to October 15 in 2016; however, your state has not enacted legislation similarly extending the time to file state tax returns. Hie proposed penalty waiver would provide taxpayers additional time to prepare their state tax returns and would alleviate the need for taxpayers to later file amended state returns correcting errors.

About Tax Executives Institute

Tax Executives Institute (TEI) is the preeminent association of in-house tax professionals worldwide and was founded in 1944 to serve the professional needs of business tax professionals. Today, the organization has 57 chapters in Europe, North and South America, and Asia, creating a global network where members from all over the world share thoughts and ideas about issues relevant to in-house tax departments. Our nearly 7,000 members represent 2,800 companies in Europe, the United States, Canada, Asia, and Latin America.

TEI members are in-house tax practitioners (accountants, lawyers and other corporate and business employees) responsible for the tax affairs of their employers in an executive, administrative, or managerial capacity. TEI espouses organizational values and goals that include integrity, effectiveness, efficiency, and dedication to improving the tax system for the benefit of taxpayers and tax administrators.

Penalty Waiver Recommendation

The complexity of the federal tax law and the resulting reporting and compliance burdens rarely allow taxpayers to file their federal income tax returns until on or shortly before the extended federal due date. The complexities created by the Tax Cuts and Jobs Act exacerbated the...