Challenging Economic Times Underscore Tei's Importance (Tax Executives Institute ) (President's Page‪)‬

On October 1, 2008, Tax Executives Institute submitted the following comments to the U.S. Department of the Treasury and the Internal Revenue Service on Notice 2008-01, relating to the treatment of certain obligations of controlled foreign corporations for purposes of section 956 of the Internal Revenue Code. The comments were prepared under the aegis of TEI's International Tax Committee whose chair is Brian C. Ugai of Starbucks Coffee Company. Tax Executives Institute commends the government for issuing Notice 2008-91, which temporarily expands to 60 days the period in which controlled foreign corporations may lend money to their U.S. shareholders without triggering section 956 of the Internal Revenue Code. Absent the notice, section 956 would generally require the U.S. shareholder to include such amounts in its taxable income because the amounts are considered "obligations" of U.S. persons.