Tax Notes Talk: Recent Episodes
Tax Notes
A discussion of cutting-edge developments in tax, including up-to-the-minute changes in federal, state, and international tax law and regulations.
Tax Notes Talk is taking a hiatus for the month of August. We’ll be back in your feed in the fall! In the meantime, be sure to check out our extensive back catalogue.
Credits**Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producer and Audio Editor: Jordan Parrish
Four international tax policy experts discuss how tax policy could strengthen Europe's technology sector and improve its global competitiveness.
For the entire discussion, watch or listen to "Bridging Europe’s Innovation Gap: Tax, Capital, and Scale."
Credits**Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producer: Jordan Parrish
Audio Editor: Laura Kondourajian
Tax Notes legal reporter Trevor Sikes investigated how the qualified tips deduction under the One Big Beautiful Bill Act has affected tipped workers in the year since the law's enactment.
Sikes and fellow legal reporter A.J. Collins interviewed the following people for this episode:
- Morgan Harms, a server at William Jeffrey’s Tavern in Arlington, Virginia
- Michael Chittenden, a lawyer with Covington and Burling
- Matt Catchpole, owner of the South Carolina restaurant group Panhandle Slam Hospitality
- Jim Toole, a clubhouse manager for the Lancaster Stormers, an American professional baseball team in Pennsylvania
For more, read Sikes and Collins' story in Tax Notes, "Check, Please: Workers React to ‘No Tax on Tips’ One Year In."
Our audio sources for this episode:
- Vice President Vance Delivers Remarks in Michigan on Tax and Spending Cuts Legislation
- Secretary Scott Bessent Testifies on Treasury Department 2027 Budget Request
- Former President Trump Holds Rally in Las Vegas
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Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producer: Jordan Parrish
Audio Editor: Laura Kondourajian
Freelance reporters Emilia Sroka and Roland Papp discuss paying taxes in Poland and Hungary and how the citizens in those countries feel about it.
Listen to the full series:
- Around the World in Taxes: the Netherlands and Brazil
- Around the World in Taxes: Greece and Italy
For more, read the tax morale series for free in Tax Notes:
- Church or State: Italian Income Taxes and Symbolic Choice
- Haratsi to I Krísi: Avoiding Taxes as an Act of Greek Patriotism
- Closing the Gaps: How Polish Local Governments Boost Tax Morale
- Carrots and Sticks: How Hungary Taught a Generation to Pay Taxes
- ‘Friendly Collection’: Brazil’s Plan to Reduce Taxpayer Mistrust
- Pay or Drown: How the Dutch Fostered Resilient Tax Compliance
Credits**Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producer: Jordan Parrish
Audio Editor: Laura Kondourajian
Freelance reporters Olaf Geurts and Bárbara Mengardo discuss paying taxes in the Netherlands and Brazil and how the citizens in those countries feel about it.
Listen to last week's episode: Around the World in Taxes: Greece and Italy
For more, read the tax morale series for free in Tax Notes:
- Church or State: Italian Income Taxes and Symbolic Choice
- Haratsi to I Krísi: Avoiding Taxes as an Act of Greek Patriotism
- ‘Friendly Collection’: Brazil’s Plan to Reduce Taxpayer Mistrust
- Pay or Drown: How the Dutch Fostered Resilient Tax Compliance
Credits**Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producer: Jordan Parrish
Audio Editor: Laura Kondourajian
Tax Notes reporter Elodie Lamer and freelance reporter Matteo Rizzi discuss paying taxes in Greece and Italy and how the citizens in those countries feel about it.
For more, read the tax morale series for free in Tax Notes:
- Church or State: Italian Income Taxes and Symbolic Choice
- Haratsi to I Krísi: Avoiding Taxes as an Act of Greek Patriotism
Credits**Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producer: Jordan Parrish
Audio Editor: Laura Kondourajian
Brandon DeBot of the Tax Law Center at New York University discusses President Trump’s lawsuit and subsequent settlement with the IRS, where things stand with the "Anti-Weaponization" Fund, and potential legal ramifications.
For more, read the following articles in Tax Notes:
- Judge Dismisses 'Anti-Weaponization' Fund Challenge as Moot
- DOJ’s Reversal on Trump Fund Proves Collusion, Former Judges Say
- Government Files Notice Refusing to Declare Trump Fund Dead
- Trump Tells Court It Has No Power to Reopen IRS Case
Credits**Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producer: Jordan Parrish
Audio Editor: Laura Kondourajian
Tax Notes reporter Kennedy Wahrmund discusses how states are increasingly turning to tax policy to address the high costs of raising children.
For more, read Wahrmund's article in Tax Notes, "Tax Policy Becoming a Key Tool in States’ Pro-Family Strategies."
Credits**Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producer: Jordan Parrish
Audio Editor: Laura Kondourajian
Tax Notes contributing editor Carrie Brandon Elliot discusses the rising interest in universal basic income, especially as artificial intelligence disrupts the job market, and the role of tax policy in paying for it.
For more, read Brandon Elliot's article, "Pandemic and Precariat: AI Courts Universal Basic Income," for free in Tax Notes.
Credits**Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producer: Jordan Parrish
Audio Editor: Laura Kondourajian
Brian Reed of Alvarez & Marsal discusses the application of the economic substance doctrine in Liberty Global Inc. v. United States and the questions raised by the Tenth Circuit's interpretation.
For more, read the following articles in Tax Notes:
- Otay Wants to Rebrief Dispute Over Basis Adjustment, IRS Says
- Liberty Global Has Tax Pros Fretting Over Planning Uncertainty
- Government Wins Economic Substance Battle in Liberty Global
Credits**Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producer: Jordan Parrish
Audio Editor: Laura Kondourajian
Four international tax policy experts discuss the details of the OECD side-by-side package deal on the global minimum tax framework and how implementation is going both in the United States and abroad.
For the entire discussion, watch or listen to "Global Minimum Tax Coordination After the Side-by-Side Agreement."
Credits**Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producer: Jordan Parrish
Audio Editor: Laura Kondourajian
Tax Notes reporters Paul Jones and Emily Hollingsworth discuss how bias in artificial intelligence can affect automated systems that select taxpayers for audits and what their investigation of California's and New York’s audit selection processes revealed.
For more, read Jones and Hollingsworth's investigation for free: "Unwatched: How State Audit Selection Systems Bypass Oversight."
Credits**Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producer: Jordan Parrish
Audio Editor: Laura Kondourajian
Three policy experts discuss the uncertain future of the OECD's global tax framework amid stalled progress and waning consensus, during a live recording from the American Bar Association Section of Taxation May meeting.
For more, read the following articles in Tax Notes:
- Slovenia Starts Piloting Submission of Pillar 2 Minimum Tax Returns
- Switzerland Weighs Delaying OECD Pillar 2 Deferred Tax Guidance
- More Work on Pillar 2 Reporting Is Needed, Treasury Official Says
Credits**Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producer: Jordan Parrish
Audio Editor: Laura Kondourajian
Professor Sakinah Tillman of the University of the District of Columbia David A. Clarke School of Law discusses how the complexities of state tax debt collections disadvantage low-income taxpayers.
For more, read Tillman's article, "Impact of Vague State Tax Collection Alternatives on Low-Income Taxpayers."
Listen to more Tax Notes Talk episodes from our critical tax theory series:
- Addressing Tax Policy Challenges for Workers With Disabilities
- The Inadvertent Price of a Gender-Neutral Tax Code
- Race-Based Poll Taxes and 20th-Century Discrimination
- Examining Treasury’s Review of Racial Bias in the U.S. Tax Code
- State Tax Authority and Native Americans: Complex and Convoluted
- Wealth, Inequality, and Taxes in the U.S.
- Taxes and the LGBTQ Community
Credits**Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producer: Jordan Parrish
Audio Editor: Laura Kondourajian
Professor Lauren Shores Pelikan of the University of Missouri School of Law discusses her proposal to create a tax benefit for individual childcare service providers to ease costs for working parents.
For more on Shores Pelikan's proposal, read "Toddlers, Investors, and Tax Policy."
For more on the LendingTree study, read "It Costs an Additional $303,418 to Raise a Child Over 18 Years, Up 1.9%."
Credits**Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producer: Jordan Parrish
Audio Editor: Laura Kondourajian
Former IRS Criminal Investigation division Chief Guy Ficco examines the agency's future, including immigration enforcement and the use of artificial intelligence, as his decades-long tenure ends.
For more on the IRS Criminal Investigation division, read the following in Tax Notes:
- IRS Criminal Investigators Pull Back From Immigration, Policing
- Firmness of IRS Voluntary Disclosure Policy Worries Tax Lawyers
- J5 Warns of Use of Crypto Platforms for Tax Evasion, Other Crimes
- IRS Shakes Up Leadership With Filing Season Looming
Credits**Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producer: Jordan Parrish
Audio Editor: Laura Kondourajian
Benjamin Angel, director of direct taxation at the European Commission’s Directorate-General for Taxation and Customs Union, discusses the EU’s biggest tax challenges right now, including windfall taxes and the side-by-side package.
For more, read the following in Tax Notes:
- EU Draft Floats Binding Measures to Reduce Electricity Taxes
- Tax Cuts Don’t Pay for Themselves, EU Commission Says
- Simplify Pillar 2-Linked Rules, Avoid DSTs, Stakeholders Tell EU
Credits**Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producer: Jordan Parrish
Audio Editor: Laura Kondourajian
Jennifer Bernardini of PwC discusses the recently released guidance for the material assistance and prohibited foreign entity rules affecting some of the clean energy credits in the One Big Beautiful Bill Act.
For more, read the following in Tax Notes:
- Dems Lay Groundwork to Restore Clean Energy Credits Post-Midterms
- GOP Bill Would Pause Clean Energy Credit to Pay for Crude Oil
- ANALYSIS: Lessons From the Energy Tax Credit Market in 2025
Credits**Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producer: Jordan Parrish
Audio Editor: Laura Kondourajian
Tax Notes senior reporter Cady Stanton investigated a provision of the low-income housing tax credit and talked to housing advocates and tenants about how a 1990s tax policy has affected affordable housing.
Stanton interviewed the following people for this episode:
- Teresa Myers, a former tenant of Rosewood Estates in Springfield, Missouri
- Jennifer Schwartz, director of tax and housing advocacy at the National Council of State Housing Agencies
- Gina Chiala, executive director and staff attorney at the Heartland Center for Jobs and Freedom
For more, read Stanton's investigation for free in Tax Notes:
- Absent Congress, Protecting LIHTC-Funded Housing Has Fallen to States
- Congress Gave Developers Flexibility. It’s Costing People Their Homes.
Credits**Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producer and Editor: Jordan Parrish
Erika Isabella Scuderi, visiting assistant professor of tax law at the University of Florida’s Levin College of Law, discusses her proposal for establishing taxing rights in outer space.
For more, read Scuderi's article, "On Sovereignty, Outer Space, and Taxation."
Credits**Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producer: Jordan Parrish
Audio Editor: Laura Kondourajian
Tax Notes contributing editor Robert Goulder discusses the Supreme Court's ruling invalidating the tariffs set in place by President Trump and what to expect for refunds.
Subscribe to History Is Taxing today for free: taxnotes.co/historypodcast
For related tax news, read the following in Tax Notes:
- New Trump Tariffs Hit With Multistate Legal Challenge
- ANALYSIS: The Real Liberation Day: IEEPA Tariffs Go Down in Flames
CreditsHost: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producer and Editor: Jordan Parrish
Tax Notes Talk presents History Is Taxing, our new podcastexploring the tax origins of today’s biggest topics, connecting the present to the past with tax experts Robert Goulder and Joseph J. Thorndike of Tax Notes.
In this episode, Goulder and Thorndike explore how America’s first tariffs shaped the nation’s fiscal policy and set the stage for today’s federal income tax.
Subscribe to History Is Taxing today for free: taxnotes.co/historypodcast
CreditsHost: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producer and Editor: Jordan Parrish
Special thanks to Christopher Trigo and Carolyn Kuimelis for their help on this episode.
U.S. Tax Court Chief Judge Patrick Urda discusses the effects of the IRS’s staff changes and generative AI on the court and its continued evaluation of online access to documents.
Listen to our episode with Judge Kerrigan: Updates From the Tax Court: Post-COVID Plans and New Funding
CreditsHost: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producer and Editor: Jordan Parrish
Tax Notes chief correspondent Stephanie Soong discusses the OECD’s recent pillar 2 side-by-side package deal and how countries are adapting to the new landscape.
For related tax news, read the following in Tax Notes:
- U.S. Focusing on OECD Guidance for Pillar 2 Side-by-Side Package
- Hungary Expands Global Minimum Tax Registration Form
- U.S. Treasury Officials Declare Death of OECD Pillar 1
CreditsHost: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes
Rozeta Atlas of HubSync discusses the IRS’s plan to overhaul its legacy IT systems and what a modernized agency may mean for practitioners.
For related tax news, read the following in Tax Notes:
- Palantir Contracts Under Scrutiny Amid IRS Tax Data Controversy
- IRS Adopts Generative Artificial Intelligence Policy
- IRS No-Paper Initiative Jammed by Staffing Issues, Watchdog Says
CreditsHost: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes
Professors Jeremy Bearer-Friend and Sarah Polcz discuss their recent paper, “Sharing the Algorithm: The Tax Solution to Generative AI,” which outlines their proposal for taxing generative AI companies.
For more, read Bearer-Friend and Polcz's article.
CreditsHost: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes
Professor Andrea Campbell, author of Taxation and Resentment: Race, Party, and Class in American Tax Attitudes, discusses why Americans' beliefs about taxes often don’t align with the specific tax policies they support.
For more on Taxation and Resentment, you can read Joseph Thorndike's book review here: "ANALYSIS: Why Do Americans Ignore Their Self-Interest When It Comes to Taxes?"
If you're interested in hearing more about Andrew Kahrl's research on the property tax, check out our episode, "Tax or Theft? Examining the History of the Property Tax."
CreditsHost: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes
Damien Martin and Tony Nitti of EY discuss the second three of their top six tax cases of 2025, focusing on what qualifies as a deduction in Savage v. Commissioner, Kelly v. Commissioner, and Weston v. Commissioner.
CreditsHost: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes
Damien Martin and Tony Nitti of EY analyze the first three of their top six tax cases from 2025, focusing on what constitutes income in CF Headquarters Corp. v. Commissioner, Franklin v. Commissioner, and Feige v. Commissioner.
CreditsHost: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes
Philip Hwang, national chair of the Taxpayer Advocacy Panel, discusses the issues the IRS and return preparers could face this filing season following the passage of the One Big Beautiful Bill Act.
For related tax news, read the following in Tax Notes:
- IRS Prepared to Meet Service, Collection Goals, Bisignano Says
- Proposed IRS Funding Cut Draws Concern From Tax Watchers
- IRS Sets Filing Season Start Date Amid Lofty Refund Expectations
CreditsHost: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes
Jaye Calhoun of Kean Miller discusses key tax issues that states will likely address in 2026, including One Big Beautiful Bill Act provisions and the adoption of artificial intelligence tools.
For related tax news, read the following in Tax Notes:
- Iowa DOR Issues Withholding Guidance on OBBBA Tax Deductions
- U.S. Chamber Backs Florida Bid to Challenge California Apportionment Rule
- States to Face Budget, Tax Policy Questions in 2026 Conformity Debate
CreditsHost: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes
Tax Analysts Chief Operating Officer Jeremy Scott reviews the 2025 developments in U.S. tax legislation and speculates what may lie ahead in 2026.
For related tax news, read the following in Tax Notes:
- These Expiring Tax Provisions Could Get Renewed in 2026
- New Deficit Projections to Hinge on Giant Tax Bill, Tariffs
- More Clean Energy Credits Are Set to Expire in 2026 Under OBBBA
- Tips and Overtime Reporting Expected to Test Employers in 2026
CreditsHost: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes
Tax Notes reporters recap some of the most memorable stories they encountered in 2025, from the establishment of a "crypto church" to how the "no tax on tips" provision may apply to certain professions.
For related tax news, read the following in Tax Notes:
- Will IRS Know Pornography When It Sees It for Tips Deduction?
- Pass Go, Collect Millions: Hasbro to Get Tax Breaks for Boston HQ
- Marital Discord Is No Defense to FBAR Penalties, U.S. Says
- Crypto Evangelist’s Tax Evasion and Other Convictions Upheld
CreditsHost: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes
Vanessa Williamson, author of The Price of Democracy, discusses her argument that the history of American fights over fiscal fairness reveals a connection between taxation and democratic power.
For more on The Price of Democracy, you can read Joseph Thorndike's book review here: "ANALYSIS: Democracy Comes With a Bill Attached: A Tax-Centered History of America."
CreditsHost: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes
Tax Notes reporters discuss updates on the biggest tax issues of the year, including the expiring Affordable Care Act credit and the Trump administration's recent tariff and trade announcements.
For related tax news, read the following in Tax Notes:
- Senate Set to Reject Dueling Bills, Leaving ACA Credit in Limbo
- New Guidance Provided on Expanded HSA Eligibility
- Trump Threatens Mexico With Tariffs Over Texas Water Spat
- House GOP Pushes Trump to Revive Tariffs on France Over DST
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This episode is sponsored by Avalara. For more information, visit avalara.com.
This episode is sponsored by Crux. For more information, visit cruxclimate.com/contact.
CreditsHost: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes
Trudy Muscat of Deloitte Malta discusses Malta's changing international tax landscape, including its adoption of the two-pillar system and recently implemented transfer pricing rules.
For more episodes from Lisbon, listen to:
- From Lisbon: The Search for Consensus on International Tax
- From Lisbon: The Future of International Tax Cooperation
- From Lisbon: Portuguese Tax Administration in the Digital Age
- From Lisbon: Highlights From the 2025 IFA Congress
For related tax news, read the following in Tax Notes:
- Bulgarian Parliament Approves Tax Treaty With Malta
- EU’s Tax Priorities Shift as Reform Stalls, Researchers Say
- MNE Profit Shifting Still Persistent, OECD Report Says
CreditsHost: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes
Juan Manuel Vázquez of Loyens & Loeff discusses the evolving international tax agenda, including ongoing pillar 2 negotiations and taxing the digital economy.
For more episodes from Lisbon, listen to:
- From Lisbon: The Future of International Tax Cooperation
- From Lisbon: Portuguese Tax Administration in the Digital Age
- From Lisbon: Highlights From the 2025 IFA Congress
For related tax news, read the following in Tax Notes:
- G20 Leaders Affirm Goal for OECD Global Minimum Tax Accord
- If Pillar 2 Directive Reopens, EU Won’t Close It, Official Says
- OECD Talks on U.S. Pillar 2 Exemption Focused on Simplification
- Italy Defends DST and Urges OECD to Restart Digital Talks
This episode is sponsored by Avalara. For more information, visit avalara.com.
CreditsHost: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes
Nominate someone for the Tax Analysts Award of Distinction in U.S. Federal Taxation! For more information, visit awards.taxanalysts.org.
Tax Notes reporters Cady Stanton and Benjamin Valdez discuss the tax credit debate that led to the government shutdown and the potential effects on the IRS and the 2026 filing season.
For related tax news, read the following in Tax Notes:
- Democrats Say It's Too Late for Any ACA Credit Alternative
- Shutdown May Hinder Filing Season Timeline, Former IRS Chiefs Say
- Republican Leaders Harden Stance Against ACA Tax Credit
This episode is sponsored by Avalara. For more information, visit avalara.com.
CreditsHost: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes
Nominate someone for the Tax Analysts Award of Distinction in U.S. Federal Taxation! For more information, visit awards.taxanalysts.org.
Tax Notes managing legal reporter Caitlin Mullaney explores the Supreme Court’s oral arguments in V.O.S. Selections and Learning Resources and predicts whether the Court will strike down President Trump’s tariffs.
For related tax news, read the following in Tax Notes:
- Michigan Agencies Forecast Tariff Impacts on Prices, Jobs
- Supreme Court Justices Question Trump's IEEPA Tariffs
- Trump-Xi Summit Yields Lower Tariffs All Around
This episode is sponsored by Avalara. For more information, visit avalara.com.
CreditsHost: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes
Nominate someone for the Tax Analysts Award of Distinction in U.S. Federal Taxation! For more information, visit awards.taxanalysts.org.
Carolyn Schenck, former IRS national fraud counsel, shares insights from decades at the agency, including her pioneering role and her recent move to private practice.
For related tax news, read the following in Tax Notes:
- Fresh Look at Exempt Orgs Could Be Good, Former CI Employee Says
- Move to Direct IRS CI at Left-Leaning Groups Is Questioned
- ‘Tax Enforcement Is Not Dead,’ Departing IRS Fraud Counsel Says
This episode is sponsored by Avalara. For more information, visit avalara.com.
CreditsHost: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes
Nominate someone for the Tax Analysts Award of Distinction in U.S. Federal Taxation! For more information, visit awards.taxanalysts.org.
Elisângela Rita, a former member of the U.N. Committee of Experts on International Cooperation in Tax Matters, discusses her career in international tax and the evolution of U.N. global tax convention discussions.
For more episodes from Lisbon, listen to:
- From Lisbon: Portuguese Tax Administration in the Digital Age
- From Lisbon: Highlights From the 2025 IFA Congress
For related tax news, read the following in Tax Notes:
- U.N. Trudges Forward on Framework Convention
- U.N. Tax Committee to Tackle Transfer Pricing, AI, Tax Nexus
- EU Commission's U.N. Tax Mandate Faces Countries' Pushback
Follow us on X:
- Sarah Paez: @PaezWrites
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
This episode is sponsored by Avalara. For more information, visit avalara.com.
CreditsHost: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes
Nominate someone for the Tax Analysts Award of Distinction in U.S. Federal Taxation! For more information, visit awards.taxanalysts.org.
Portuguese Tax and Customs Authority General Director Helena Alves Borges discusses the agency’s modernization efforts and preparation for pillar 2.
For more episodes from Lisbon, listen to "From Lisbon: Highlights From the 2025 IFA Congress."
For more tax news, read the following in Tax Notes:
- More Countries Still Considering Amount B Adoption
- OECD Building Out Work on AI Usage in Tax Administration
- EU Wants Its U.S. Subsidiaries to Be Subject to Top-Up Tax
Follow us on X:
- Stephanie Soong: @StephanieSoong
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
This episode is sponsored by Avalara. For more information, visit avalara.com.
Join us at the inaugural Tax Trends Summit in Washington, D.C. presented by Tax Notes and the ABA Tax Section. For more information, visit taxnotes.co/taxtrends25.
CreditsHost: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes
Nominate someone for the Tax Analysts Award of Distinction in U.S. Federal Taxation! For more information, visit awards.taxanalysts.org.
Tax Notes contributing editor Robert Goulder discusses the upcoming oral arguments before the Supreme Court on the validity of the Trump administration's recent reciprocal tariffs and speculates on the Court's reaction.
For more tax news and analysis, read the following in Tax Notes:
- Nonprofits Urge SCOTUS to Side With Trump Admin in Tariff Dispute
- President Can Impose Tariffs Under IEEPA, Admin Tells SCOTUS
- ANALYSIS: V.O.S. Selections, Part 2: Will SCOTUS Rescue Trump's Tariffs?
- ANALYSIS: V.O.S. Selections, Part 1: Are Trump's Tariffs 'Too Big to Fail'?
- Supreme Court Will Hear Trump's Appeal of Tariff Rulings
Follow us on X:
- Robert Goulder: @RobertGoulder
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
This episode is sponsored by Avalara. For more information, visit avalara.com.
Join us at the inaugural Tax Trends Summit in Washington, D.C. presented by Tax Notes and the ABA Tax Section. For more information, visit taxnotes.co/taxtrends25.
CreditsHost: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes
Tax Notes reporter Sarah Paez breaks down the biggest international tax developments from the annual Congress of the International Fiscal Association in Lisbon, Portugal.
For more coverage, read the following in Tax Notes:
- OECD Plans 2026 Draft on Transfer Pricing Guidelines Revisions
- EU Wants Its U.S. Subsidiaries to Be Subject to Top-Up Tax
- ESG Ratings Don’t Inform Tax Risk, HMRC Official Says
- Pillar 2 Permanent Safe Harbor Talks Focused on Integrity Issues
Follow us on X:
- Sarah Paez: @PaezWrites
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
This episode is sponsored by Avalara. For more information, visit avalara.com.
Join us at the inaugural Tax Trends Summit in Washington, D.C. presented by Tax Notes and the ABA Tax Section. For more information, visit taxnotes.co/taxtrends25.
CreditsHost: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes
April Harding, former IRS director of user experience services, discusses her proposed agency modernization plan and the future of IRS digital products.
For more coverage, read the following in Tax Notes:
- Shutdown Uncertainty Adds to Difficult Year for IRS Employees
- Direct File Derailed by Dissension, Not Performance, Werfel Says
- What's Next for the IRS? Another Overhaul?
Follow us on X:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
This episode is sponsored by Avalara. For more information, visit avalara.com.
Join us at the inaugural Tax Trends Summit in Washington, D.C. presented by Tax Notes and the ABA Tax Section. For more information, visit taxnotes.co/taxtrends25.
CreditsHost: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes
Karen Kelly, former acting assistant attorney general of the Justice Department Tax Division, discusses the upcoming elimination of the division and how it could affect civil and criminal tax enforcement.
For more coverage, read the following in Tax Notes:
- House Bill Would Formalize Abolition of DOJ Tax Division
- Tax Community Pushes to Keep DOJ Tax Division Intact
- Idea to Disperse DOJ Tax Lawyers Draws Mixed Initial Reaction
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This episode is sponsored by Avalara. For more information, visit avalara.com.
CreditsHost: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
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Professors David Gamage and Darien Shanske discuss their recent paper, “Money Moves: Taxing the Wealthy at the State Level,” which lays out their argument for a state-level wealth tax.
For more, read Gamage and Shanske's article, coauthored by Professor Brian Galle.
For more coverage, read the following in Tax Notes:
- U.K. Labour Deputy Leader Hopeful Campaigns for Wealth Taxes
- Report on 16,500 Millionaires Quitting U.K. 'May Be Fabricated'
- Tax Justice Network Report Urges Wealth Tax for Climate Finance
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This episode is sponsored by Avalara. For more information, visit avalara.com.
CreditsHost: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes
Tax Notes contributing editors Robert Goulder and Joseph Thorndike discuss the recent Nvidia deal to export chips to China, and they question its constitutionality and implications.
For more coverage, read the following in Tax Notes:
- ANALYSIS: The Nvidia Affair: So Now We're Taxing Exports?
- ANALYSIS: Trump’s Nvidia Deal Is Almost Certainly Unconstitutional — Not That It Matters
- White House Eyes Replicating Nvidia Deal for Other Industries
- Nvidia Deal Sparks Dismay From Tax Observers
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CreditsHost: David D. Stewart
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Former IRS Chief Privacy Officer Kathleen Walters discusses the agency’s data sharing agreement with the Department of Homeland Security, her decision to step down, and life as a working mom.
For more coverage, read the following in Tax Notes:
- Treasury Looks to Undo Some IRS Resignations
- IRS Posts Thousands of Jobs Amid Workforce Reductions
- IRS Has Answered Immigration Agency's Request for Tax Data
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CreditsHost: David D. Stewart
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Tax Notes contributing editor Robert Goulder discusses how Pope Leo XIV’s American citizenship creates a unique tax issue and how the United States may try to avoid taxing the pope.
For more coverage, read the following in Tax Notes:
- Expats Eye Pope's Tax Woes as Opportunity to Ditch Worldwide Tax
- Analysis: The American Pope and Citizenship-Based Taxation
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CreditsHost: David D. Stewart
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Tax Notes contributing editor Ryan Finley discusses the current transfer pricing landscape, including where things stand in the Facebook and Coca-Cola cases.
For more coverage, read the following from Finley in Tax Notes:
- Analysis: The CUT Method: It's Not What It Used to Be
- Analysis: The CUT Method: Same as It Ever Was?
- Analysis: On Periodic Adjustments, Facebook Opinion Suggests A Middle Road
- Analysis: For the IRS, Facebook Is a Reminder to Stick to the Script
- Analysis: Medtronic II: Do the Transfer Pricing Regs Swallow Themselves?
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CreditsHost: David D. Stewart
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Ellen Aprill of UCLA discusses the legal battle between Harvard and the Trump administration over the university's tax-exempt status and the recourses that an exempt organization may have if its status is revoked.
For more, read Aprill's article, "Revoking Tax Exemption for Pursuit of DEI and Other Alleged Forms of Discrimination."
For more coverage, read the following in Tax Notes:
- Flood of New Briefs Support Ending Johnson Amendment Restrictions
- Senate Dems Seek Probe of Trump's Challenge to Harvard's Exemption
- Trump Questions Harvard's Tax-Exempt Status
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CreditsHost: David D. Stewart
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Steve Kralik of Armanino discusses the One Big Beautiful Bill Act’s implications for state tax, including the new version of the SALT cap and how states may conform to the changes.
For more coverage, read the following in Tax Notes:
- Colorado Faces $1.2 Billion Revenue Loss From OBBBA Provisions
- California Advances Conformity Update Bill Without OBBBA Provisions
- Trump Tax Bill Brings State Funding Dilemmas, Conformity Choices
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CreditsHost: David D. Stewart
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Alan Cole of the Tax Foundation discusses the international tax provisions in the One Big Beautiful Bill Act and what may be next for negotiations on a global tax framework.
For more on international tax and the OBBBA, check out our previous episode, "International Tax in the Reconciliation Bill: House Versus Senate."
For more coverage, read the following in Tax Notes:
- Tax Pros Hope for Regs to Resolve One-Month Deferral Quandary
- What's in a Word? Tax Pros Puzzle Over FTC Allocations
- Analysis: The OBBBA's International Revenue Raisers, Losers, and Fixes
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CreditsHost: David D. Stewart
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House Ways and Means Committee member Adrian Smith, R-Neb., discusses the One Big Beautiful Bill Act’s accomplishments and what could be next for Congress on tax.
Check out our interview with Rep. Horsford, "House Taxwriter Talks Democratic Priorities, Responds to OBBBA."
For more coverage, read the following in Tax Notes:
- Lawyers Predict Reconciliation Bill Tax Controversies
- House Appropriators Would Cut IRS Beyond White House's 20 Percent
- New GOP Tax Law Will Add $3.4 Trillion to the Deficit, CBO Says
- GOP's 'No Tax on Tips' Falls Short for Las Vegas Taxwriter
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House Ways and Means Committee member Steven Horsford, D-Nev., discusses the New Democrat Coalition’s tax priorities and the framework the coalition developed as an alternative to the One Big Beautiful Bill Act.
Check out our break down of the passed legislation, "The One Big Beautiful Bill Act: What Made the Final Cut?"
For more coverage, read the following in Tax Notes:
- One Big Beautiful Bill Redux Could Be '2 Big 2 Beautiful'
- Trump's Order Creates Uncertainty for Clean Energy Tax Credits
- Democrat's Effort to Roll Back Gambling Deduction Cap Fails
- Trump Got His Tax Bill. Now the Task Will Be Implementing It.
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Tax Notes Capitol Hill reporters Cady Stanton and Katie Lobosco explore the final version of the One Big Beautiful Bill Act that President Trump signed into law on July 4.
For more coverage, read the following in Tax Notes:
- Revenge Tax Ghost Looms Over G7’s Pillar 2 Deal
- Trump Tax Bill Brings State Funding Dilemmas, Conformity Choices
- OBBBA Is the Biggest Tax Bill Ever. Why Doesn’t It Feel Like It?
- Trump Got His Tax Bill. Now the Task Will Be Implementing It.
- Trump Signs Bill to Make Most of TCJA Permanent
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Ryan Minnick of the Federation of Tax Administrators discusses how state tax agencies are approaching artificial intelligence and shares insights from the FTA’s upcoming briefing paper on generative AI and its 2024 tax agency survey.
For more coverage, read the following in Tax Notes:
- California Tax Agency Ramping Up for Generative AI
- State Tax Administrators Are Studying the Use of Generative AI
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Tax Notes investigations editor Lauren Loricchio discusses Treasury’s information sharing agreement with the Department of Homeland Security and its implications for immigrants.
Read Loricchio's full story in Tax Notes, "Information Sharing Deal Complicates Immigrant Return Filing."
For more on what's been happening at the IRS, check out our previous episodes:
- Past IRS Commissioners Analyze Agency Changes Under Trump
- IRS Automated Guidance: Pros and Cons
- Behind the Story: Investigating the Faults in the IRS's FOIA System
- The Latest at the IRS: Personnel Changes, More Staff Reductions
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Have you or a peer made a lasting impact on state and local tax policy? Nominations for the 2025 Tax Analysts State and Local Tax Award of Distinction are open. For more information or to nominate someone, go to taxnotes.co/awards.
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Jonathan Samford and Kevin Klein of the Global Business Alliance discuss the proposed section 899 retaliatory tax and other international tax provisions included in the Senate version of the One Big Beautiful Bill Act.
For more on the bill, check out our previous episodes:
- In The Zone: Changes to Opportunity Zones in the House Budget Bill
- One Big Beautiful Bill: Breaking Down the House Tax Package
- The House Budget Bill’s Clean Energy Tax Credit Changes
For more coverage, read the following in Tax Notes:
- Senate GOP Opts for International Tax Regime Redesign
- Expect More Changes in Reconciliation Tax Bill, Senators Say
- U.K. Worried About U.S. Revenge Tax, OECD Pillar Negotiations
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Have you or a peer made a lasting impact on state and local tax policy? Nominations for the 2025 Tax Analysts State and Local Tax Award of Distinction are open. For more information or to nominate someone, go to taxnotes.co/awards.
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Jessica Millett of Hogan Lovells discusses the proposed changes to the Opportunity Zone program under the House version of the One Big Beautiful Bill Act and how the Senate might react.
For more on the One Big Beautiful Bill Act, check out our previous episodes:
- One Big Beautiful Bill: Breaking Down the House Tax Package
- The House Budget Bill’s Clean Energy Tax Credit Changes
For more coverage, read the following in Tax Notes:
- Several Tax Issues Remain Unresolved for Senate Republicans
- Analysis: New Opportunities for Opportunity Zones in the Big Beautiful Bill
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Have you or a peer made a lasting impact on state and local tax policy? Nominations for the 2025 Tax Analysts State and Local Tax Award of Distinction are open. For more information or to nominate someone, go to taxnotes.co/awards.
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Former IRS Commissioners Lawrence Gibbs, John Koskinen, Charles Rettig, and Daniel Werfel share lessons learned from their tenures and predictions for the agency's future under the new administration.
For the full discussion, check out our Taxing Issues episode, "Reimagining the IRS: A Historic Conversation."
For more coverage, read the following in Tax Notes:
- IRS Clawback Fight Moves to Reconciliation, Appropriations
- Senate Panel Advances IRS Nominee; Final-Vote Timeline Unclear
- Trump Proposal Would Eclipse Scandal-Era Cuts to IRS Enforcement
- Former Officials Troubled by Pace of IRS Data Sharing Efforts
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Have you or a peer made a lasting impact on state and local tax policy? Nominations for the 2025 Tax Analysts State and Local Tax Award of Distinction are open. For more information or to nominate someone, go to taxnotes.co/awards.
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Tax Notes Capitol Hill reporters Cady Stanton and Katie Lobosco discuss the final version of the House’s reconciliation bill and what’s next as the legislation heads to the Senate.
Listen to our previous episode on the bill's clean energy credit changes, "The House Budget Bill’s Clean Energy Tax Credit Changes."
For more coverage, read the following in Tax Notes:
- Senate Must Make Tricky Process Decision for Tax Bill Changes
- House Adds Tweak to Partnership Disguised Sale Statute
- Senators Eye Changes to SALT Cap, Permanency in Tax Bill
- House Adds Head-Scratching Tweaks to International Tax Regime
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Have you or a peer made a lasting impact on state and local tax policy? Nominations for the 2025 Tax Analysts State and Local Tax Award of Distinction are open. For more information or to nominate someone, go to taxnotes.co/awards.
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Jenny Speck with Vinson & Elkins discusses the clean energy tax credits in the House’s One Big Beautiful Bill Act, including last-minute changes to the House Rules Committee’s version.
For more coverage, read the following in Tax Notes:
- House Advances $3.8 Trillion Tax Bill; Faces Rewrite in Senate
- Democratic Dads Say Tax Bill Would Pass Debt Burden to Kids
- Clean Energy Industry Seeks Edits to Tax Bill
- Analysis: The Future of IRA Credit Transfers: Predictions From the First Year
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Have you or a peer made a lasting impact on state and local tax policy? Nominations for the 2025 Tax Analysts State and Local Tax Award of Distinction are open. For more information or to nominate someone, go to taxnotes.co/awards.
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Four policy experts discuss the Trump administration’s actions on tariffs, their economic impacts, and their effects on tax policy during a live recording from the American Bar Association Section of Taxation May meeting.
For more coverage, read the following in Tax Notes:
- Tax Experts: Two Thumbs Down for Federal Film Credits, Tariffs
- U.S. and China Reach Trade Agreement, Roll Back Tariffs
- Tariffs Scrapped on Steel and Aluminum in U.K.-U.S. Trade Deal
- Tariffs, Economic Change Add to Pressure on GOP Tax Bill
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Have you or a peer made a lasting impact on state and local tax policy? Nominations for the 2025 Tax Analysts State and Local Tax Award of Distinction are open. For more information or to nominate someone, go to taxnotes.co/awards.
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Tax Notes chief correspondent Stephanie Soong discusses how the Trump administration’s tax priorities have been shaping negotiations on the OECD’s two-pillar project.
Listen to our previous episodes on the two pillars here:
- Former U.S. OECD Negotiator Talks Trump's Global Tax Impact
- Making Progress: Updates on the OECD Tax Reform Plan
- An Update on Pillar 1 Amount B
- Pillar 1 Amount B: Disagreements and Divides
For more coverage, read the following in Tax Notes:
- EU Tax Observatory Urges More Talks on Pillar 2 Tax Incentives
- Stakeholders Back Mix of Pillar 2 Tweaks to Reassure the U.S.
- EU Presidency Lays Out Options to Address U.S. Pillar 2 Concerns
- GILTI’s Coexistence With OECD Global Minimum Tax Is U.S. Priority
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Professors Joshua Blank and Leigh Osofsky, authors of Automated Agencies: The Transformation of Government Guidance, discuss the IRS and other federal agencies’ use of artificial intelligence and chatbots in providing legal guidance to the public.
For more coverage, read the following in Tax Notes:
- State Tax Administrators Are Studying the Use of Generative AI
- IRS to Pause Technology Modernization Work
- ATO Urged to Integrate Ethical, Legal Safeguards Into AI Models
- IRS Artificial Intelligence Policy Could See Changes Under Trump
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Join the Tax Notes Talk team for our upcoming live recording at the ABA May Tax Meeting on Friday, May 9!
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Tax Notes Capitol Hill reporters Cady Stanton and Katie Lobosco outline Congress’s progress on drafting the tax-focused reconciliation bill and the obstacles still remaining.
For more coverage, read the following in Tax Notes:
- The Semi-Calm Before the Storm of Assembling a Giant Tax Bill
- Those Troublesome Budget Instructions: They Might Not Matter
- House Looks to Assert ‘First Mover’ Status on Tax Bill
- Senate Taxwriters Discussing Hike in Top Tax Rate, Grassley Says
- How House Budget Hawks Went From ‘No’ to ‘Yes’ in Under 24 Hours
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This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
Join the Tax Notes Talk team for our upcoming live recording at the ABA May Tax Meeting on Friday, May 9!
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Tax Notes chief correspondent Amanda Athanasiou discusses her recent investigation into the IRS's handling of Freedom of Information Act requests and trends from two decades of agency data.
For more, check out the Tax Notes coverage of the IRS FOIA system:
- IRS FOIA Backlog Expected to Grow
- FOIA Appeals Fail So Often, Taxpayers See a Broken System
- The IRS Is Getting Fewer FOIAs. Why Aren’t Response Times Improving?
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This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
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Mat Mermigousis of BDO discusses the Trump administration’s ever-changing tariff policies and what they may mean for U.S. businesses.
For more coverage, read the following in Tax Notes:
- Trump Pauses Tariff Increases
- EU Poised to Impose 25 Percent Retaliatory Tariffs on U.S. Goods
- China Announces Reciprocal Tariffs on U.S. Imports
- Trump’s Tariffs Generate Tons of Criticism as Uncertainty Abounds
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This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
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Professor Andrew Kahrl, author of The Black Tax: 150 Years of Theft, Exploitation, and Dispossession in America, discusses his argument that local property taxes have contributed to the disenfranchisement of Black homeowners.
Read Thorndike's book review in Tax Notes, "Is the ‘Predatory’ Property Tax an Instrument of Oppression?"
Listen to more Tax Notes Talk episodes from our critical tax theory series:
- Addressing Tax Policy Challenges for Workers With Disabilities
- Race-Based Poll Taxes and 20th-Century Discrimination
- Examining Treasury’s Review of Racial Bias in the U.S. Tax Code
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This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
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Kimie Eacobacci of the National Council on Disability details how a 60-year-old revenue ruling can exclude workers with disabilities from standard employment benefits and protections.
Listen to more Tax Notes Talk episodes from our critical tax theory series:
- The Inadvertent Price of a Gender-Neutral Tax Code
- Race-Based Poll Taxes and 20th-Century Discrimination
- Examining Treasury’s Review of Racial Bias in the U.S. Tax Code
- State Tax Authority and Native Americans: Complex and Convoluted
- Wealth, Inequality, and Taxes in the U.S.
- Taxes and the LGBTQ Community
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****This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
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Tax Notes IRS reporter Benjamin Valdez provides an update on the IRS’s recent staffing developments and how they may affect filing season.
Check out our most recent episode on the IRS, "Trump's Hiring Freeze and the IRS."
For more coverage, read the following in Tax Notes:
- IRS Rollout of In-Person Work Faces Obstacles
- Treasury, IRS Still Finalizing Next Staff Reductions, Krause Says
- IRS to Pause Technology Modernization Work
- Trump Replaces Acting IRS Chief Counsel
- Ousted IRS Human Capital Officer Pushed Back on Firings, DOGE
- Former IRS Officials Warn of Consequences to Staff Cuts
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This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
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Melissa Wiley of Kostelanetz LLP provides an update on the Corporate Transparency Act’s legal status after Treasury announced it would not enforce penalties against domestic companies.
Listen to our previous episodes on the CTA:
- The Corporate Transparency Act: Recent Challenges and Confusion
- Navigating the Corporate Transparency Act
For more coverage, read the following in Tax Notes:
- Corporate Transparency Act Found to Violate Fourth Amendment
- Treasury Announces Shift in CTA Focus to Foreign Companies
- FinCEN Pauses Beneficial Ownership Reporting Penalties
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****This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
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In the third of a three-part series, Damien Martin and Tony Nitti of EY discuss their top tax cases from 2024, focusing on two C corp cases: Ju et al v. United States and Stead v. Commissioner.
Watch the first two parts of the series:
- Top Tax Cases of 2024, Part 1: Partnerships
- Top Tax Cases of 2024, Part 2: S Corporations
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This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
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In the second of a three-part series, Damien Martin and Tony Nitti of EY discuss their top tax cases from 2024, focusing on two S corp cases: Maggard v. Commissioner and Estate of Thomas Fry et al v. Commissioner.
Watch the first part of the series, "Top Tax Cases of 2024, Part 1: Partnerships."
For more coverage, read the following in Tax Notes:
- Tax Court Rejects Engineer’s S Corp Dissolution Defense
- ABA Pushes for More Guidance on S Corp Reorganizations
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This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
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In the first of a three-part series, Damien Martin and Tony Nitti of EY discuss their top tax cases from 2024, focusing on two partnership cases: Denham Capital Management LP v. Commissioner and Surk LLC v. Commissioner.
For more coverage, read the following in Tax Notes:
- DOJ Touts Tax Court Win on Limited Partner Exception
- Tax Pros Weigh Impact of Ruling on IRS Basis Calculation Method
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This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
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Tax Notes contributing editor and historian Joseph J. Thorndike discusses President Trump’s referral to “the forgotten man” and how the phrase connects to a conservative case for taxing the rich.
Read Thorndike's article in Tax Notes, "The Too-Well-Remembered Man: A Conservative Case for Taxing the Rich."
For more coverage, read the following in Tax Notes:
- Bye-Bye Round Numbers, Hello Rate Tweaks for Rescored TCJA Bill
- Movement on Trump Tax Proposals Is Reconciliation Wild Card
- Moores' Counsel Says Case Signals Court Is Not Open to Novel Taxes
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This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
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Audio Engineers: Jordan Parrish, Peyton Rhodes
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Robert Kerr, formerly with the IRS and now with Kerr Consulting, discusses the recent federal hiring freeze and buyout offer and speculates how they may affect the IRS.
Listen to our previous episode on how Trump's executive orders relate to international tax, "Former U.S. OECD Negotiator Talks Trump's Global Tax Impact."
For more coverage, read the following in Tax Notes:
- IRS Claims Filing Season Staff Are Exempt From Buyout
- Fiscal 2026 Budget Cycle Could Be Critical for IRS Funding Path
- Federal Hiring Freeze Quickly Hits Prospective IRS Attorneys
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This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
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Scott Levine, former Treasury deputy assistant secretary for international tax affairs, discusses President Trump’s executive order on the OECD’s global tax deal and its potential impact on the two-pillar project.
Listen to our previous episodes on the two pillars here:
- Making Progress: Updates on the OECD Tax Reform Plan
- An Update on Pillar 1 Amount B
- Pillar 1 Amount B: Disagreements and Divides
- Manal Corwin Takes the Helm: Updates on the OECD Tax Reform Plan
For more coverage, read the following in Tax Notes:
- Official Highlights Importance of Amount B Amid Undecided Future
- Economist Warns U.S. Rejection of Global Minimum Tax Hurts EU
- House Republicans Reintroduce Anti-Pillar 2 Legislation
- EU Laments Trump's Disregard for OECD's Global Tax Plan
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This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
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Tax Notes investigations editor Lauren Loricchio discusses security concerns regarding tax software platforms’ data-sharing practices.
Read Loricchio's article, "Monetization of Tax Data Sparks Concerns About Security."
For additional coverage, read the following articles in Tax Notes:
- Taxpayer Data Leak Investigations Rarely Lead to Prosecutions
- ProPublica Data Leak Lawsuit Ends in Settlement
- IRS Discussing Response to Data Sharing by Tax Prep Companies
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****This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
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Lili Martin-Mashburn of Morris, Manning & Martin provides an update on where the Corporate Transparency Act stands in light of the recent litigation regarding its constitutionality.
Listen to our previous episode on the CTA, "Navigating the Corporate Transparency Act."
For more coverage, read the following in Tax Notes:
- Once Again, District Court Finds CTA Likely Unconstitutional
- 25 States Side With Businesses in Transparency Act Challenges
- Fifth Circuit Puts Corporate Transparency Act Back on Hold
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****This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
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Two state tax policy experts discuss key tax proposals that states will likely address in 2025, including efforts to raise revenue and extend provisions of the Tax Cuts and Jobs Act.
For additional coverage, read these articles in Tax Notes:
- Massachusetts Adopts Reg Changes on Apportionment, Married Filers
- Idaho Governor Pledges to Continue Providing Tax Relief
- Leaked Docs ID Taxes Washington Senate Democrats Could Consider
- COST Report Shows Modest State and Local Business Tax Growth
- Washington Governor's Final Budget Adds to Calls for Wealth Taxation
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****This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
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Tax Analysts Chief Operating Officer Jeremy Scott reviews the 2024 developments in U.S. tax legislation and speculates what may lie ahead in 2025.
For additional coverage, read these articles in Tax Notes:
- Direct File Expected to Face Scrutiny by Incoming Administration
- Tax Bill Uncertainty May Dampen Business Activity
- What to Expect From Scoring the 2025 Tax Bill
- The Coming Tax Package: To Count Tariffs or Not
- IRS Hiring Poised to Be Tested by Trump’s Remote Work Disapproval
- Trump Policy Priorities Could Push Tax Into the Back Seat
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****This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
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Tax Notes reporters recap some of the most memorable stories they encountered in 2024, from “pig butchering” scams to a denied late-filing excuse citing Christmas stress.
For additional coverage, read these articles in Tax Notes:
- Maine Enacts Tax Credit to Keep Portland Baseball Team
- DraftKings Kills Betting Tax Surcharge Proposal
- DraftKings Announces Surcharge Plan on States With High Betting Taxes
- 'Pig Butchering' Theft Losses May Evade TCJA Restrictions
- Mega Win for British Snack Company in VAT Dispute
- British Supermarket Owes VAT on Food Bars, U.K. Tribunal Finds
- Nutrition Company Owes VAT on Protein Foods, U.K. Tribunal Finds
Listen to other tax oddities episodes:
- Year-End Collection: Tax Oddities of 2023
- Year-End Collection: Tax Oddities of 2022
- Year-End Collection: Tax Oddities of 2021
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Tax Notes chief correspondent Stephanie Soong recaps the latest updates from the OECD’s two-pillar project and highlights what is expected from the organization in 2025.
Listen to our previous episodes on the two pillars here:
- An Update on Pillar 1 Amount B
- Pillar 1 Amount B: Disagreements and Divides
- Manal Corwin Takes the Helm: Updates on the OECD Tax Reform Plan
- Bringing Order to Chaos? Digital Services Taxes and Pillar 1
For more coverage, read the following in Tax Notes:
- IRS to Propose Regs on OECD Amount B Transfer Pricing Approach
- IRS Wants to Preserve DCL Regime Election Amid Pillar 2 Rules
- OECD Transitional Pillar 2 Tax Peer Review Nearing Completion
- UAE to Introduce OECD-Aligned Domestic Minimum Top-Up Tax
- Australian Senate Approves Package of Global Minimum Tax Bills
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Tony Santiago, founder and president of TaxSearch Inc., discusses the future of tax leadership and his recommendations for tax departments looking to create an effective succession plan.
Listen to our previous episode on tax succession, "Paving the Way for the Next Generation of Tax Professionals."
For additional coverage, read Santiago's articles in Tax Notes:
- Tax Department Leadership: Effective Succession Strategies
- Best Practices for Recruiting Critical Tax Roles
- Optimizing Tax Talent in Challenging Times
- Evaluating Critical Remote Arrangements in Corporate Tax Departments
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A Tax Notes investigation unveiled how money sheltered in offshore insurance investment vehicles has eluded IRS auditors hampered by poor training and silos within the agency.
Leaked documents obtained by the International Consortium of Investigative Journalists and reviewed by Tax Notes show private placement life insurance structures — a special type of insurance available only to wealthy investors — with millions of dollars set up in offshore tax havens like Belize and the Cayman Islands.
Three members of the Tax Notes investigations team explain their reporting process, from choosing the topic to final follow-ups.
If you have a tip for the investigations team, reach them at tips.investigations@taxnotes.com or through the Signal app at 347-731-3183.
For more, check out the team's coverage on private placement life insurance:
- Chance of Changes to Life Insurance ‘Wrappers’ Dims Postelection
- How Offshore Life Insurance Helps Business Owners Minimize Taxes
- High-End Life Insurance Policies Lured Offshore by Relaxed Rules
- Inside How Private Placement Life Insurance Slips Through the Cracks
To hear Senator Wyden's full statement, visit https://www.youtube.com/watch?v=xiez_NnUBZQ.
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In an exclusive sit-down interview with Tax Notes Talk, IRS Commissioner Daniel Werfel discusses his tenure and the agency’s future with major Tax Cuts and Jobs Act provisions expiring next year.
For more coverage, read the following in Tax Notes:
- IRS Is Well Positioned to Handle Tax Bill, Werfel Says
- IRS Council Calls for Public Education About Tax Noncompliance
- IRS to Beef Up Artificial Intelligence Oversight Structure
- Election Results Cast Doubt on Fate of IRS Funding, Direct File
- Werfel Says Agency Is Gearing Up to Weigh In on TCJA Expiration
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Jānis Taukačs, a partner at Sorainen in Latvia, discusses the Baltic region’s tax priorities, as well as his own professional journey through the world of tax.
For other episodes from Cape Town, listen to:
- "From Cape Town: A Sit-Down With South Africa's Top Tax Official."
- "From Cape Town: Developing Tax Policy for Developing Nations."
For more about the Sergei Magnitsky story, read David Stewart's article in Tax Notes, "Death of Russian Lawyer Puts Spotlight on Hermitage Tax Fraud."
For more coverage, read the following in Tax Notes:
- OECD Framework Discussing Permanent Pillar 2 Safe Harbors
- Frustration Persists in OECD Framework Over Pillar 1
- Lithuania Tax Authority Proposes Pillar 2 Implementing Rules
- Latvian Parliament Passes Global Minimum Tax Legislation
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Professor Afton Titus of the University of Cape Town explains her view on how the tax initiatives of the OECD and United Nations affect developing nations.
For other episodes from Cape Town, listen to "From Cape Town: A Sit-Down With South Africa's Top Tax Official."
For more coverage, read the following in Tax Notes:
- Trump Win Casts Shadow Over OECD Global Tax Reforms
- OECD Framework Discussing Permanent Pillar 2 Safe Harbors
- Frustration Persists in OECD Framework Over Pillar 1
- U.N. Official Floats Cooperation With OECD on Tax Dispute Issues
- New U.N. Model Tax Treaty Article Is a Win for Developing Countries
- Bilateral Treaty Sourcing Rules Harm Developing Countries, Paper Says
For information about our live Taxing Issues event, visit: https://events.taxanalysts.org/tawebinar112024
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South African Revenue Service Commissioner Edward Kieswetter discusses his tenure leading the agency and the country’s position in the modernization of the international tax system.
For more coverage, read the following in Tax Notes:
- DSTs Could Violate Tax Treaty Obligations, U.N. Official Says
- EU Commission Fully Supports Permanent Pillar 2 Safe Harbor
- OECD Framework Discussing Permanent Pillar 2 Safe Harbors
- Frustration Persists in OECD Framework Over Pillar 1
- U.N. Official Floats Cooperation With OECD on Tax Dispute Issues
- New U.N. Model Tax Treaty Article Is a Win for Developing Countries
- South African Tax Chief Warns Taxing Right Fight Will Intensify
For information about our live Taxing Issues event, visit: https://events.taxanalysts.org/tawebinar112024
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Tax Notes contributing editor Robert Goulder shares his take on the effects of the Foreign Account Tax Compliance Act and common reporting standards on the feasibility of taxing foreign assets.
Listen to our previous episodes on taxing hidden assets:
- The Constitutionality of Penalties on Undeclared Assets
- America the Tax Haven? Exploring the U.S. Trade Deficit
For more coverage, read the following in Tax Notes:
- Trump Vows to End ‘Double Taxation’ of Overseas Citizens
- Court Tells DOJ No Do-Over in Venture Capitalist FBAR Case
- EU, Belgium Say Domestic Bank Secrecy Hinders Tax Transparency
- U.S., Switzerland to Exchange Info Under New FATCA Deal From 2027
- IRS Approves Argentina’s Data Security for FATCA Exchanges
- Transparency Not a Threat to Privacy, Tax Justice Network Says
For information about our live Taxing Issues event, visit: https://events.taxanalysts.org/tawebinar112024
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Monisha Santamaria and Nick Tricarichi of KPMG discuss the scope of the latest guidance on the corporate alternative minimum tax and its impact on tax and accounting professionals.
Listen to our previous episode on CAMT: Navigating New Guidance on the Corporate Alternative Minimum Tax
For more coverage, read the following in Tax Notes:
- Exempt Orgs Get Temporary Break From Filing Corporate AMT Form
- Corrections Coming for Corporate AMT Proposed Regs
- Treasury Downplays FTC Timing Concerns in Corporate AMT Regs
- More Corporate AMT Safe Harbors Are on the Table
- Analysis: CAMTyland Adventures, Part V: Coping With CAMTyland Grief
For information about our live Taxing Issues event, visit: https://events.taxanalysts.org/tawebinar112024
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Tax Notes White House reporter Alexander Rifaat discusses the tax policies proposed by Vice President Kamala Harris and former President Trump.
For more coverage, read the following in Tax Notes:
- Trump Proposes Tax Write-Off for Generator Purchases
- Trump Proffers Tax Incentives for Car Owners, Manufacturers
- Trump’s Plan Would Swell Deficit More Than Harris’s, Study Says
- No Indication Vance Will Release Tax Returns
- Harris Proposes New Manufacturing Tax Credit
- Unrealized Capital Gains Proposal Faces Uncertain Path
- Harris Says ‘Trump Tax’ Would Cost Americans $4,000 Annually
- Harris Held Talks With Union Before Making Tip Pledge
Audio clips obtained from C-SPAN.
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Tax Notes contributing editor Robert Goulder discusses the history of foreign bank account reporting penalties and how two recent court cases could affect the FBAR regime.
For more coverage, read the following in Tax Notes:
- Jury Finds Professor’s FBAR Failures Willful
- FBAR Penalty Circuit Split Has Potential for Supreme Court Review
- Schwarzbaum FBAR Penalty Dispute Results in Circuit Split
- Court Tells DOJ No Do-Over in Venture Capitalist FBAR Case
- Ninth Circuit Approves Prejudgment Interest for FBAR Penalties
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Professors Kenneth Austin and Hillel Nadler discuss the policies that they believe make the United States a tax haven, and the resulting effects on the economy.
For more, read Nadler and Austin's article in Tax Notes, "America the Tax Haven and Its Trade Deficits."
Listen to more Tax Notes Talk episodes about tax havens:
- Bad Credit: A Look at Switzerland’s Bank Secrecy
- Let’s Talk Tax Havens: The EU Blacklist and the Pandora Papers
For more coverage, read the following in Tax Notes:
- EU to Remove Antigua and Barbuda From Tax Blacklist
- Researchers Try to Quantify Firms’ Use of Tax Havens After TCJA
- BEPS Activity May Have Declined in Tax Havens, OECD Reports
- Montana DOR Amends Code to Remove Tax Haven Language
- The EU Tax Blacklist: A Six-Year Journey Toward Compliance
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Tax Notes contributing editor Nana Ama Sarfo discusses methane-related tax policy and how it might lead to future taxation of greenhouse gas emissions.
For more on taxing greenhouse gases, listen to Is Carbon Pricing the Best Way to Mitigate Climate Change?
For additional coverage, read Sarfo's analysis in Tax Notes: The Future of Carbon Taxes Could Lie in Methane
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Tax Notes contributing editor Ryan Finley breaks down the EU Court of Justice’s recent ruling that Ireland granted €13 billion of unlawful state aid to Apple and its implications for state aid analysis.
For more coverage, read the following in Tax Notes:
- Irish Finance Minister Defends Tax System After Apple Decision
- CJEU Reinstates €13 Billion State Aid Decision Against Apple
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Alan McLean, chair of the tax committee at Business at OECD, discusses the developments in the international business tax world during his tenure and the committee’s priorities.
Listen to our episode with Will Morris, former chair of the tax committee, here: The Tax Diplomat: Reflections From Former BIAC Tax Chair
For more coverage, read the following in Tax Notes:
- OECD Targets Country Benefits That May Weaken Pillar 2 Rules
- Businesses Call for Central Platform for Global Minimum Tax Data
- GLOBE Permanent Safe Harbor Idea May Boost EU Competitiveness
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Do you have questions about tax policy in the 2024 election? Submit your questions here.
Steve Rosenthal of the Urban-Brookings Tax Policy Center and Don Susswein of RSM discuss how Congress should handle agency delegation following the Loper Bright decision.
For more from Rosenthal and Susswein, read the following:
- Congress Can Maintain IRS Rulemaking Authority
- What About Vague ‘Delegated’ Tax Regulations?
For additional coverage, read the following articles in Tax Notes:
- DOJ, FedEx Contest Loper Bright’s Effect in Offset Earnings Case
- Loper Bright Casts Doubt on SECA Guidance Plan, Tax Pros Say
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Do you have questions about tax policy in the 2024 election? Submit your questions here.
Tax Notes Capitol Hill reporters Cady Stanton and Doug Sword assess the tax policy items on Congress’s slate this fall, from IRS funding to TCJA extenders, and the potential implications of the upcoming elections.
For additional coverage, read these articles in Tax Notes:
- Tax Extenders Menu Heavy With Energy, Business Tax Breaks
- Tax Package Could Be Useful Lame-Duck Launching Point
- Lengthy Tax Extender Wish List Awaits Lame-Duck Session
- House GOP Taxwriters Warn of Impacts From Letting TCJA Expire
- Trump Makes Murky Claim of Quadrupled Taxes if TCJA Expires
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Javiera Moraga Valverde, a Chilean lawyer and U.S. law firm associate, discusses her research on how tax systems can harm women via gender-neutral tax policies and shares potential solutions.
For more, read Moraga Valverde's article in Tax Notes, "Tax Policy: Is Gender Neutrality Enough?"
Listen to more Tax Notes Talk episodes from our critical tax theory series:
- Gender Equality, Tax, and the Pandemic
- Race-Based Poll Taxes and 20th-Century Discrimination
- Examining Treasury’s Review of Racial Bias in the U.S. Tax Code
- Is IRS Tax Enforcement Colorblind?
- State Tax Authority and Native Americans: Complex and Convoluted
- Wealth, Inequality, and Taxes in the U.S.
- Feminism and the Tax Code
- Taxes and the LGBTQ Community
- Addressing Racial Inequity in State and Local Tax Policy
- The Tax Code and Economic Justice in America
- How Racial Diversity Shaped U.S. International Tax Policy
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Sarah Lora of Lewis & Clark Law School discusses the personal exemption after the Tax Cuts and Jobs Act and the implications for immigrant families with nonresident dependents.
For more, read Lora's paper, "Righting Tax Wrongs for Immigrants."
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Leslie McLean, director of the low-income taxpayer clinic at DNA-People’s Legal Services, discusses the barriers Navajo Nation members face when filing their taxes and attempting to claim credits.
Listen to the first episode in this series, "The Tax Challenges of the Navajo Nation, Part 1."
Read Investigations Editor Lauren Loricchio's series:
- Legislation, Outreach Could Help Tribal Taxpayers Access Tax Credits
- Scarce Resources Leave Navajo Nation With Few Tax Options
For additional coverage, read the following articles in Tax Notes:
- W&M Advances Tribal Child Support Enforcement Bill
- Inside the IRS Representation Roadblock Facing Navajo Nation
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Tax Notes investigated the Navajo Nation’s tax challenges with the IRS and gathered firsthand accounts of how its members navigate a complex filing system with scarce resources and cultural differences.
Investigations Editor Lauren Loricchio interviewed two members of the Navajo Nation: Laura Mike, executive director of the Navajo United Way, and Buu Nygren, president of the Navajo Nation. She also spoke with Nick Mattison, a partner at Feferman, Warren & Mattison, who specializes in consumer law.
For additional coverage, read the following articles in Tax Notes:
- W&M Advances Tribal Child Support Enforcement Bill
- Inside the IRS Representation Roadblock Facing Navajo Nation
- Legislation, Outreach Could Help Tribal Taxpayers Access Tax Credits
- Scarce Resources Leave Navajo Nation With Few Tax Options
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- Lauren Loricchio: @LaurenLoricchio
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George Ford with the Phoenix Center for Advanced Legal and Public Policy Studies discusses film tax incentives and their effectiveness in attracting business to states.
Read Ford's article, "Asking the Right Questions About Film Tax Incentives."
For additional coverage, read the following articles in Tax Notes:
- Maryland Tax Credit Encouraged Apple Production to Film In-State
- Michigan House Committee Approves Film Tax Credit Legislation
- Accountants and Aliens: California Bags 15 Film Projects With Tax Credit
- Georgia's Film Tax Credit Is Bigger and More Costly Than Ever, Report Says
- New York Clarifies Eligibility for Expanded Film Tax Credit
- Louisiana DOR Issues Guidance on Film Tax Credit Changes
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Tax Notes contributing editor Marie Sapirie discusses the recent Supreme Court decisions overturning Chevron and defining the statute of limitations period and their potential impact on the future of tax litigation.
Listen to our relatedepisodes:
- Less Is Moore: The Supreme Court's Ruling in Moore v. United States
- Pending Supreme Court Cases and the Challenges for Tax Policy
- What the End of Chevon Deference May Mean For Tax
For additional coverage, read the following articles in Tax Notes:
- YA Global Pushes Tax Court to Revisit Withholding Decision
- Analysis: Chevron Is Dead. Long Live Skidmore and the APA?
- Post-Chevron Senate Group Deluging 101 Agencies With Letters
- Loper Bright Puts Direct File on Shakier Ground, Crapo Says
- House GOP Chairs Flood Agencies With Loper Bright Questions
- Tribune: Loper Bright Merits Review of Partnership Antiabuse Reg
- Supreme Court’s Overturning of Chevron Could Cause Tax Shake-Up
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- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
CreditsHost: David D. Stewart
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Ted Peterson of the University of North Texas Ryan College of Business discusses the SALT deduction cap and its potential paths forward as the 2025 sunset date approaches.
Read Peterson's article, "The SALT Cap: Looking Beyond 2025."
Listen to our previous episode on the SALT cap, "Recapping States’ SALT Cap Workarounds."
For additional coverage, read the following articles in Tax Notes:
- Hawaii Enacts Fixes for SALT Cap Workaround
- California Senate OKs Change to SALT Cap Workaround Rules
- Ways and Means Launches Tax Teams Ahead of 2025 TCJA Expirations
- It’s Policy vs. Politics in 2025’s Super Bowl of Tax
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Tax Notes chief correspondent Amanda Athanasiou discusses the effectiveness of carbon pricing as a climate change mitigation strategy and possible alternative policies.
Read Athanasiou's article, "Keeping the Promise of Carbon Taxes in Perspective."
Listen to our previous episode on carbon pricing, "Taxing Carbon at the Border."
For additional coverage, read the following articles in Tax Notes:
- Canada's Budget Watchdog Reveals Gag on Carbon Tax Data
- Carbon Pricing Systems Collected Highest Revenues in 2023
- Political Messaging Doesn't Aid Carbon Tax Acceptance, Study Says
- Carbon Prices Work but the Literature Has Gaps, Study Says
- France Joins Canada's Emissions Pact Amid Carbon Tax Backlash
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- David Stewart: @TaxStew
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Tax Notes managing legal reporter Andrew Velarde breaks down the Supreme Court's decision in Moore v. United States and its implications for the future of tax.
To hear from the Moores' lawyers, watch the upcoming Taxing Issues webinar here.
Listen to our previous Moore episodes:
- A Recap of SCOTUS Oral Arguments in Moore v. United States
- Moore Money, More Tax Problems? Analyzing Moore v. United States
For additional coverage, read these articles in Tax Notes:
- Moores' Counsel Says Case Signals Court Is Not Open to Novel Taxes
- Supreme Court Says Transition Tax Is Constitutional in Narrow Ruling
- Analysis: What's at Stake With Moore v. United States: Transcript
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- David Stewart: @TaxStew
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Tax Notes reporter Sarah Paez discusses the proposed tax plans from the United Kingdom’s political parties before their upcoming July 4 election.
For more coverage, read these articles in Tax Notes:
- Tories, Labour, Lib Dems Make Tax Pitches to SMEs
- U.K. Labour Vows to Improve EU Trade Terms, No Council Tax Reform
- Tories Say Labour Will Hike U.K. Capital Gains Tax Post-Election
- U.K. Labour Party's Tax Plans Could Raise Over £8 Billion
- U.K. Conservatives Plan Further Cuts to Employee Taxes
For more of Dan Neidle's tax coverage, visit taxpolicy.org.uk.
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Nina Olson of the Center for Taxpayer Rights and the Tax Analysts board of directors discusses the challenges in preserving taxpayer rights in light of increasing digitalization by the IRS and tax preparation companies.
For more coverage, read these articles in Tax Notes:
- IRS Seeks to Procure Artificial Intelligence Tools
- IRS Modernization Effort Seen as Lacking Transparency
- IRS to Make Direct File Permanent, Expand It Nationwide
- IRS Nears Decision on Fate of Direct File; Free File Extended
- Analysis: The IRS Errs in Its Use of Math Error Procedures
- ABA Section of Taxation Meeting: Head of Free File Questions Need for Direct File
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Susan Lanham, Amanda Thompson-Abbott, and Tom Norton of Marshall University discuss their research on the earned income tax credit’s effectiveness in alleviating poverty.
For more, read Lanham, Thompson-Abbott, and Norton's Tax Notes article, "Assessing the EITC’s Role in Poverty Alleviation."
For more coverage, read these articles in Tax Notes:
- CBO Analysis of Taxpayer Race Data Shows Disparities
- Refundable Credit Audits Should Reflect Equity, GAO Says
- Data Could Help IRS Evaluate ‘Racialized Burdens’
- Tax Prep Industry Bashes ‘Outdated’ EITC Report
- Retail Tax Prep Companies Accused of Targeting Minorities
- GAO Finds $22 Billion Sent in Error for Earned Income Tax Credit
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- Alex Rifaat: @alexrifaat
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CreditsHost: David D. Stewart
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Alysse McLoughlin and Katie Quinn of Jones Walker discuss state tax implications of the Inflation Reduction Act’s clean energy credits.
For more episodes on the Inflation Reduction Act energy credits, listen to:
- IRA Energy Credits, Part 2: Proposed Regs and What’s Next
- IRA Energy Credits, Part 1: History and Early Guidance
For more coverage, read these articles in Tax Notes:
- IRS Guidance Amps Up Clean Electricity Tax Credit Flexibility
- Analysis: A Trap for the Unwary Purchaser of an IRA Credit
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- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
CreditsHost: David D. Stewart
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Monte Jackel of Jackel Tax Law discusses partnership taxation rules and the role they play in former President Trump’s ongoing IRS audit.
For more, read the article from ProPublica and The New York Times, "IRS Audit of Trump Could Cost Former President More Than $100 Million."
For more on Trump's taxes, listen to Trump’s Tax Returns and the Future of Transparency.
For additional coverage, read these articles in Tax Notes:
- Analysis: The Worthlessness Deduction for Partnership Interests: An Unguided Missile
- Analysis: Assets-Over Merger Blunders on Negative Adjustments
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- Tax Notes: @TaxNotes
CreditsHost: David D. Stewart
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Tax Notes senior legal reporter Nathan Richman discusses the tax implications of the recent financial controversies surrounding Los Angeles Dodgers player Shohei Ohtani and his former translator.
For additional coverage, read these articles in Tax Notes:
- Ohtani’s Ex-Translator Agrees to Plead Guilty to Tax Charge
- Tax May Still Come to Bat in Saga of Ohtani’s Translator
- California Proposal Would Urge Congress to Block Ohtani-Type Deferred Pay
- Ohtani's Dodgers Contract Draws California Controller's Ire
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- David Stewart: @TaxStew
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CreditsHost: David D. Stewart
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Libin Zhang and Kristin Hickman discuss the broader implications of Moore v. United States and the challenges to the Chevron doctrine during a live recording from the American Bar Association Section of Taxation May meeting.
For related episodes, listen to:
- What the End of Chevron Deference May Mean for Tax
- A Recap of SCOTUS Oral Arguments in Moore v. United States
For additional coverage, read these articles in Tax Notes:
- Late Chevron Challenge to Split-Dollar Regs Falls Flat
- States Are Moving Away From Judicial Deference, Practitioners Say
- Post-Arguments, Moore Effect on Wealth Tax Still Up for Debate
- Government May Have Upper Hand in Moore, but Court May Go Narrow
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CreditsHost: David D. Stewart
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Mary Wood of Meadows Collier discusses recent updates on the employee retention credit, from the IRS’s moratorium on new claims to the potential effect of pending legislation.
For more episodes on the employee retention credit, listen to:
- IRS Key Updates: ERC, EITC, and Government Shutdown Plans
- The Employee Retention Credit: Scams and Successes
For additional coverage, read these articles in Tax Notes:
- Pandemic Relief Fraud Scheme Shut Down, TIGTA Says
- IRS Leaves Door Open to Resume ERC Voluntary Disclosure
- ERC Voluntary Disclosure Program Barrels Toward Uncertain End
- ERC Abuse Revives Debate Over Contingency Fees
- IRS ERC Audits Undergo Changes as They Get Older
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- Lauren Loricchio: @LaurenLoricchio
- David Stewart: @TaxStew
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CreditsHost: David D. Stewart
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Professor Yariv Brauner of the University of Florida Levin College of Law discusses the challenges facing residence-based taxation and his proposal for a new way to tax individuals.
For more, read Brauner's article, "Taxing People, Not Residents."
In our “Editors’ Corner” segment, Andrey Yushkov, senior policy analyst for the Tax Foundation, chats about his coauthored Tax Notes piece, “Long-Term Trends in State Personal Income Tax.”
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- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
This episode is sponsored by PLI Press. For more information, visit pli.edu/taxnotes.
Join the Tax Notes Talk team for our upcoming live recording at the ABA May Tax Meeting on Friday, May 3! Fore more information, visit taxnotes.co/aba.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Frank Agostino of Agostino & Associates discusses two pending Supreme Court cases, their potential effects on the Chevron doctrine, and their implications for the tax world.
Listen to our latest episode on Moore here: A Recap of SCOTUS Oral Arguments in Moore v. United States For additional coverage, read these articles in Tax Notes:
- Late Chevron Challenge to Split-Dollar Regs Falls Flat
- States Are Moving Away From Judicial Deference, Practitioners Say
- Petitioner Asks SCOTUS to Hold Case Until Chevron Is Decided
- A Look Ahead: Penalty Approval Issues Likely Won’t Be Solved Through Regs
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- MK Browne: @mk_browne10
- David Stewart: @TaxStew
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This episode is sponsored by PLI Press. For more information, visit pli.edu/taxnotes.
Join the Tax Notes Talk team for our upcoming live recording at the ABA May Tax Meeting on Friday, May 3! Fore more information, visit taxnotes.co/aba.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Tax Analysts' chief economist Martin Sullivan discusses the Congressional Budget Office’s latest economic forecast, new insights on the effects of the Tax Cuts and Jobs Act, and what all this means for tax policy.
For more, read Sullivan's analysis, "Economists Find Little Growth and Worsening Inequality From TCJA."
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- Martin Sullivan: @M_SullivanTax
- David Stewart: @TaxStew
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****This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
This episode is sponsored by PLI Press. For more information, visit pli.edu/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Tax Notes contributing editor Nana Ama Sarfo discusses the SEC’s recently released carbon pricing disclosure rules and their reception from the business community.
For additional coverage, read Sarfo's article in Tax Notes, "Examining the SEC’s Simpler Carbon Pricing Disclosure Rules."
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- Nana Ama Sarfo: @nanaama_sarfo
- David Stewart: @TaxStew
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****This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
This episode is sponsored by PLI Press. For more information, visit pli.edu/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
William McRae of Cleary Gottlieb discusses the U.S. Tax Court’s decision in YA Global Investments v. Commissioner and what it means for the private equity sector.
For additional coverage, read these articles in Tax Notes:
- Tax Pro Questions Tax Court’s Dealer Analysis in YA Global
- Tax Pros Weigh Impact of YA Global on Fund Industry
- YA Global Footnote Shouldn’t Be Overlooked
- Cayman Islands Hedge Fund Liable for Tax Bill of Over $57 Million
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- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
****This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Tax Notes Capitol Hill reporters Cady Stanton and Doug Sword discuss the roadblocks the Tax Relief for American Families and Workers Act is facing in the Senate.
For additional coverage, read these articles in Tax Notes:
- Crapo’s Tax Deal Offers Were Non-starters for Dems, Wyden Says
- Finance Republicans Have Problem With Tax Bill’s Retroactivity
- Wyden Warns It’s Now or Never for R&D and Other Biz Tax Breaks
- Larger Priorities and Slow Discussions Leave Tax Bill in Limbo
- Tax Deal Doesn’t Have Support to Skirt Filibuster, Crapo Says
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- Cady Stanton: @cady_stanton
- Doug Sword: @doug_sword
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
****This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Tax Notes chief correspondent Stephanie Soong discusses the latest developments surrounding amount B under pillar 1 of the OECD’s two-pillar corporate tax reform plan.
Listen to our last podcast on amount B: Pillar 1 Amount B: Disagreements and Divides
For additional coverage, read these articles in Tax Notes:
- Amount B Transfer Pricing Approach Doesn’t Deliver, BIAC Says
- Amount B Might Have a Phase 2, Bello Says
- Amount B Won’t Change Australia’s Inbound Distributor Approach
- New Zealand Won’t Adopt Amount B Transfer Pricing Framework
- OECD Sets Out Amount B Transfer Pricing Simplification Framework
- Amount B Tax Certainty Is a Red Line for U.S., Bello Says
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- Stephanie Soong: @StephanieSoong
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
****This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Christine Green of Steptoe & Johnson PLLC discusses the Corporate Transparency Act and the recent litigation regarding its constitutionality.
For additional coverage, read these articles in Tax Notes:
- U.S. Court Declares Corporate Transparency Act Unconstitutional
- Yellen: New Beneficial Ownership Reporting Rules Already Working
- FinCEN Finalizes Access Rule for Beneficial Ownership Reporting
- IRS Criminal Investigators Won’t Enforce New Transparency Rules
- FinCEN Finalizes Reporting Extension Rule Without More Relief
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- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
****This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Tax Notes contributing editor Ryan Finley discusses the latest developments in three transfer pricing cases — Medtronic, 3M, and Abbott Labs — and their implications for the future.
For additional coverage, read these articles in Tax Notes:
- Business Groups Urge Eighth Circuit to Overturn Tax Court in 3M
- Medtronic Budges on CUT Method in Round 2 at Eighth Circuit
- Abbott Labs Revives Fight Over Stock Options in Transfer Pricing
- Blocked Brazilian Income Can’t Be Taxed in U.S., 3M Brief Argues
- 3M Challenges Blocked Income Regs at Eighth Circuit
- Government Resumes Defense of Its Transfer Pricing for Medtronic
- Coca-Cola’s Brazilian Income Not Blocked, U.S. Tax Court Says
In our “Editors’ Corner” segment, Edith Brashares, former director in the Treasury Office of Tax Analysis, chats about her coauthored Tax Notes piece, “Is the Economic Analysis Section of Regs Worth the Trouble?”
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
****This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Professors Edward Fox and Zachary Liscow discuss their proposal for a new tax on billionaires that would apply to borrowing against their assets.
For more, read Fox and Liscow's article, "No More Tax-Free Lunch for Billionaires: Closing the Borrowing Loophole," in Tax Notes.
For more on wealth taxes, listen to The Wealth Tax Debate.
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- Robert Goulder: @RobertGoulder
- David Stewart: @TaxStew
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****This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Tax Notes Capitol Hill reporters Cady Stanton and Doug Sword discuss the key provisions of the Tax Relief for American Families and Workers Act and its potential paths for passage in the Senate.
For additional coverage, read these articles in Tax Notes:
- House Kills SALT Marriage Penalty Bill in Procedural Vote
- Smith Combats Claims Senate Republicans Weren’t in Tax Talks
- Senate Border Traffic Jam Pushes Tax Bill Back Weeks, at Least
- House Tax Deal Vote Hasn’t Swayed Senators Seeking Markup
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- Cady Stanton: @cady_stanton
- Doug Sword: @doug_sword
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
****This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
For more information on Ask Blue J, visit bluej.com/ask.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Professor Roberta Mann of the University of Oregon School of Law explains how taxing single-use plastics could help combat their environmental effects.
For more, read Mann's article, "Targeting Plastic Pollution with Taxes."
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- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
****This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
This episode is sponsored by TaxBandits. For more information, visit taxbandits.com and use promo code TaxNotes5.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Tax Notes managing legal reporter Andrew Velarde discusses the economic substance doctrine dispute in Liberty Global Inc. v. United States and its potential implications.
For previous Moore episodes, listen to the following:
- A Recap of SCOTUS Oral Arguments in Moore v. United States
- Moore Money, More Tax Problems? Analyzing Moore v. United States
For additional coverage, read these articles in Tax Notes:
- ABA Section of Taxation Meeting: Liberty Global Is a Warning Against High-Level Business Purpose
- Liberty Global Appeals Economic Substance Loss to Tenth Circuit
- Liberty Global Promises Economic Substance Doctrine Appeal
- Economic Substance Doctrine Constrains Liberty Global
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
****This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
This episode is sponsored by TaxBandits. For more information, visit taxbandits.com and use promo code TaxNotes5.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Kelly Phillips Erb, known online as Taxgirl, discusses the 2024 filing season’s challenges and considerations in light of the IRS’s post-IRA funding changes and the potential for congressional action on a tax deal.
For additional coverage, read these articles in Tax Notes:
- IRS Hasn’t Been Idle During ERC Moratorium
- IRS Launches Direct-File Platform
- Hopes for Senate Markup of Tax Deal Complicated by Timing
- IRS Unveils Sleeker Notices Ahead of Filing Season
- Tax Deal Puts a Damper on Filing Season Optimism
- Werfel: Shutdown During Filing Season Could Be ‘Very Disruptive’
- Filing Season Tax Changes Could Be Challenging for Direct File
Follow us on Twitter:
- Jonathan Curry: @jtcurry005
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
****This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
This episode is sponsored by TaxBandits. For more information, visit taxbandits.com and use promo code TaxNotes5.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Tax Notes contributing editor Robert Goulder discusses the downward attribution dispute in Altria Group Inc. v. United States and the case’s similarities to Moore.
Listen to our Moore episodes:
- A Recap of SCOTUS Oral Arguments in Moore v. United States
- Moore Money, More Tax Problems? Analyzing Moore v. United States
For additional coverage, read these articles in Tax Notes:
- Analysis: The Excise Power: Altria Waits Its Turn
- Altria’s Case Stayed Pending Realization Decision in Moore
- Altria Challenges IRS Downward Attribution Control Analysis
Follow us on Twitter:
- Robert Goulder: @RobertGoulder
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
****This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
This episode is sponsored by TaxBandits. For more information, visit taxbandits.com and use promo code TaxNotes5.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Tax Notes contributing editor Nana Ama Sarfo discusses global tax transparency efforts, specifically beneficial ownership registries and country-by-country public reporting.
For more, read Sarfo's analysis in Tax Notes: New Year, New Expectations for Global Tax Transparency
Follow us on Twitter:
- Nana Ama Sarfo: @nanaama_sarfo
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
****This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
This episode is sponsored by the Tax Attorney Recruiting Event. For more information, visit the-tare.com.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Stephanie Do of the Council On State Taxation discusses key state tax policy topics that are likely to see action in 2024, including the expiration of Tax Cuts and Jobs Act provisions.
For additional coverage, read these articles in Tax Notes:
- West Virginia Governor Highlights Fiscal 2024 Revenue
- COST Urges California High Court to Block Taxation of Intangibles
- The High Cost of Untaxed Sales
- SALT Cap Workarounds Are Not Always Beneficial, Practitioner Says
- Stakeholders: More Clarifications Needed for New Mexico's Digital Ad Rules
- Voters Reject Wealth Taxes in Texas, Approve Pot Tax in Ohio
- New and Revised Guidance on GILTI, FDII Available in New Jersey
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
****This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
This episode is sponsored by the Tax Attorney Recruiting Event. For more information, visit the-tare.com.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Tax Analysts Chief Operating Officer Jeremy Scott reviews the 2023 developments in U.S. tax legislation and speculates what may lie ahead in 2024.
For more on AI and the Big 4, read this Fortune article.
For additional coverage, read these articles in Tax Notes:
- Businesses Paid More Taxes in Fiscal 2022, COST Report Says
- A Look Ahead: If a Tax Package Materializes, Don’t Blink or You’ll Miss It
- The Biggest Implications of Moore
- IRS Looks to Procure AI Operations Platform
- IRS Cautioned to Be Careful in the Face of Clawbacks
- Republican Taxwriters Push for Expired TCJA Tax Provision Work
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Tax Notes reporters recap some of the strangest stories they encountered in 2023, from a video game that can prepare tax returns to the IRS attempting to seize a 200-year-old Italian cello.
For additional coverage, read these articles in Tax Notes:
- The ‘Gamification’ of Tax Return Preparation Has Arrived
- Tax Wonk Calls Foul on Massachusetts Surtax After NBA Player Departs
- Taxpayer Hits Sour Note in Quest to Protect Cello From IRS Levy
- Forged Documents Shatter Iranian Seizure Deduction Claim
- Strained Vacation Locales Embrace Tourism Taxes
Listen to other tax oddities episodes:
- Year-End Collection: Tax Oddities of 2022
- Year-End Collection: Tax Oddities of 2021
- Year-End Collection: Tax Oddities of 2020
Follow us on Twitter:
- Caitlin Mullaney: @MullaneyWrites
- Emily Hollingsworth: @EmilyHoll9
- Sarah Paez: @PaezWrites
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Tax Notes managing legal reporter Andrew Velarde breaks down the Supreme Court's oral arguments in Moore and predicts what's next for the case.
For additional coverage, read these articles in Tax Notes:
- Government May Have Upper Hand in Moore, but Court May Go Narrow
- Moore Sold Shares in Transition Tax Company for Big Gain
- Moores Fire Back That Macomber Is Controlling, Not Mere Dictum
- Transition Tax Drafter: Quit It With ‘Mandatory Repatriation Tax’
- Small Business Groups Enter the Moore Fray in Defense of the Tax
- Moore Amicus Offers Supreme Court Off-Ramp From Realization Query
- Macomber Dictum Not Controlling in Moore, Government Says
Listen to our previous Moore episode: Moore Money, More Tax Problems? Analyzing Moore v. United States
To hear the full oral arguments, visit supremecourt.gov/oral_arguments/argument_audio/2023
In our “Editors’ Corner” segment, Błażej Kuźniacki, senior manager at the International Tax Services at PwC Netherlands, chats about his Tax Notes piece, “Pillar 2 and International Investment Agreements: ‘QDMTT Payable’ Seals an Internationally Wrongful Act.”
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
In honor of Tax Notes Talk's 300th episode, Tax Notes chief correspondent Stephanie Soong reviews her tax career and coverage of the OECD over the last decade.
For additional coverage, read these articles in Tax Notes:
- Pillar 1 Treaty Safe Harbor May Fall Short of Goals, Group Says
- EU Won’t Introduce Pillar 1 Directive, Commission Official Says
- Canada’s Position on Digital Tax Is Unchanged, Freeland Says
- More European Governments Propose Global Minimum Tax Bills
- Kuwait Signs Up to OECD Inclusive Framework and Tax Reform Plan
- Belgium Sends Draft Pillar 2 Legislation to Parliament
- Countries Are Still at Pillar 1 Negotiating Table, Corwin Says
Listen to our 200th and 100th episodes:
- 200 Episodes: Tax Notes Talk's Defining Interviews
- Tax Notes Goes To Court (Again)
Follow us on Twitter:
- Stephanie Soong: @StephanieSoong
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Tax Notes chief correspondent Amanda Athanasiou discusses the growing global popularity of carbon border adjustment mechanisms, the EU’s new regime, and how border adjustments can be used to support carbon pricing and environmental policy.
For additional coverage, read these articles in Tax Notes:
- Official Defends EU CBAM Against Developing Countries' Critiques
- Australia Considers CBAM in Carbon Leakage Measures Consultation
- Norway Isn't Obligated to Implement EU CBAM, Government Says
- EU Tax Commissioner Seeks to Reassure CBAM Critics
- Non-EU Countries Push Back on CBAM at WTO Forum
- EU Adopts CBAM Reporting Requirements
- EU Wants Input on CBAM Phase-In Rules
- European Parliament Approves Carbon Border Adjustment Mechanism
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the Tax Attorney Recruiting Event. For more information, visit the-tare.com.
This episode is sponsored by the FRA Private Investment Fund Tax & Accounting Forum. For more information, visit fraconferences.com/pif.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Wally Hellerstein of the University of Georgia Law School discusses the emerging state guidance for taxing cryptoassets.
For more on the taxation of cryptoassets, listen to "Cryptocurrency and the Newly Proposed Tax Rules on Digital Assets."
For additional coverage, read these articles in Tax Notes:
- OECD Cryptoasset Framework to Come Into Force in 2027
- New Jersey Tax Division: Crypto, NFTs Are Financial Products
- New York Attorney General Proposes to Tighten Crypto Industry Rules
- The State of NFTs: Navigating the Taxation of Digital Assets
- State Guidance on Cryptocurrency and NFTs Needed, Panel Says
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
****This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.This episode is sponsored by the FRA Private Investment Fund Tax & Accounting Forum. For more information, visit fraconferences.com/pif.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Tax Notes contributing editor Nana Ama Sarfo discusses how lawmakers across the globe are looking to taxes to address problems with fast fashion.
For additional coverage, read Sarfo's analysis for free in Tax Notes: "The Tax Man Comes for Fast Fashion."
Follow us on Twitter:
- Nana Ama Sarfo: @nanaama_sarfo
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
****This episode is sponsored by the FRA Private Investment Fund Tax & Accounting Forum. For more information, visit fraconferences.com/pif.
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
This episode is sponsored by the Tax Attorney Recruiting Event. For more information, visit the-tare.com.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Sanessa Griffiths of Skadden, Arps, Slate, Meagher & Flom LLP discusses the lack of diversity in the tax bar and recommends ways to fix it.
For more, read Griffiths et al's article, "Diversity in the Tax Bar — Reflections on Lessons Learned and the Path Forward."
For the report mentioned in the intro, visit "Goal III Report 2022."
Listen to more Tax Notes Talk episodes from our critical tax theory series:
- Race-Based Poll Taxes and 20th-Century Discrimination
- Examining Treasury’s Review of Racial Bias in the U.S. Tax Code
- Is IRS Tax Enforcement Colorblind?
- State Tax Authority and Native Americans: Complex and Convoluted
- Wealth, Inequality, and Taxes in the U.S.
- Feminism and the Tax Code
- Taxes and the LGBTQ Community
- Addressing Racial Inequity in State and Local Tax Policy
- The Tax Code and Economic Justice in America
- How Racial Diversity Shaped U.S. International Tax Policy
Follow us on Twitter:
- Caitlin Mullaney: @MullaneyWrites
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
****This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
This episode is sponsored by the FRA Private Investment Fund Tax & Accounting Forum. For more information, visit fraconferences.com/pif.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Mike Resnick of Eversheds Sutherland discusses the effects on taxpayers of the corporate alternative minimum tax and its recently released guidance.
For additional coverage, read these articles in Tax Notes:
- Proposed Regs for Corporate AMT Will Address Partnership Shares
- Corporate AMT Consolidation Rules Flow From Tax Principles
- Financial Firm Highlights Potential for Corporate AMT Distortion
- Treasury Official Explains Confusing Rule in Corporate AMT Notice
- Corporate AMT Depreciation Tweaks Unsurprising but Welcome
- Guidance Fills In Some Blanks on Corporate AMT
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
****This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
This episode is sponsored by the Tax Attorney Recruiting Event. For more information, visit the-tare.com.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
In the second of a two-episode series, Tim Jacobs of Hunton Andrews Kurth continues his discussion of the energy credits enacted in the Inflation Reduction Act and the proposed regulations.
Listen to the first part of this series: IRA Energy Credits, Part 1: History and Early Guidance
For additional coverage, read these articles in Tax Notes:
- Grouping Rule Could Be Added to Clean Energy Prefiling Process
- Energy Department Opens Portal for Low-Income Bonus Energy Credit
- Analysis: Apprentices and Emergency Repairs
- Analysis: For U.S. Territories, IRA Credits Remain a Complicated Question
- Analysis: Proposed Labor Requirement Regs Contain Few Surprises
In our “Editors’ Corner” segment, Michael Semes, professor of practice in the graduate tax program at the Charles Widger School of Law at Villanova University and of counsel at BakerHostetler, chats about his coauthored Tax Notes piece, “ADP Certiorari Denial Increases SaaS Uncertainty.”
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
****This episode is sponsored by the University of Cincinnati. For more information, visit online.uc.edu/taxation.
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
In the first of a two-episode series, Tim Jacobs of Hunton Andrews Kurth discusses the energy credits enacted in the Inflation Reduction Act and the major pieces of guidance released so far.
Listen to our other episodes on the tax-related provisions in the Inflation Reduction Act:
- The New Excise Tax on Corporate Stock Buybacks
- U.S. Tax Provisions Driving the Fight Against Climate Change
- $80 Billion in New Funding: What’s Next for the IRS?
- Analyzing the Corporate Alternative Minimum Tax
For additional coverage, read these articles in Tax Notes:
- Analysis: Apprentices and Emergency Repairs
- Analysis: For U.S. Territories, IRA Credits Remain a Complicated Question
- Analysis: Proposed Labor Requirement Regs Contain Few Surprises
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
****This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
This episode is sponsored by the University of Cincinnati. For more information, visit online.uc.edu/taxation.
This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxstrategies23.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Tax Notes reporter Elodie Lamer discusses the Business for Europe: Framework for Income Taxation (BEFIT) initiative, the European Commission’s latest plan to harmonize and streamline certain aspects of corporate taxation.
For additional coverage, read these articles in Tax Notes:
- Analysis: BEFIT for Europe: Must We Do This Again?
- Global Developments Both Helped and Constrained EU’s BEFIT
- European Commission Draws Lessons From Past Failures With BEFIT
- BEFIT to Apply to Pillar 2 Groups, Align Transfer Pricing Rules
- EU Businesses Want More Involvement in BEFIT Preparations
Follow us on Twitter:
- Elodie Lamer: @ElodieLamer
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
****This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
This episode is sponsored by the University of Cincinnati. For more information, visit online.uc.edu/taxation.
This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxstrategies23.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Professor Jeremy Bearer-Friend of the George Washington University Law School discusses poll taxes in the 20th century and how they were used to target taxpayers based on race and ethnicity.
For more, read Bearer-Friend's article, "Race-Based Tax Weapons."
Listen to more Tax Notes Talk episodes from our critical tax theory series:
- Examining Treasury’s Review of Racial Bias in the U.S. Tax Code
- Is IRS Tax Enforcement Colorblind?
- State Tax Authority and Native Americans: Complex and Convoluted
- Wealth, Inequality, and Taxes in the U.S.
- Feminism and the Tax Code
- Taxes and the LGBTQ Community
- Addressing Racial Inequity in State and Local Tax Policy
- The Tax Code and Economic Justice in America
- How Racial Diversity Shaped U.S. International Tax Policy
Follow us on Twitter:
- Joe Thorndike: @jthorndike
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
****This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
This episode is sponsored by the University of Cincinnati. For more information, visit online.uc.edu/taxation.
This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxstrategies23.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Robert Kerr, formerly with the IRS and now with Kerr Consulting, discusses latest developments from the IRS, including the tax agency’s plans for a government shutdown and its handling of the employee retention credit.
For additional coverage, read these articles in Tax Notes:
- Looming Shutdown Threatens to Derail IRS’s Progress
- IRS Isn’t Shutdown-Proof After All
- IRS to Scale Back EITC Audits, Citing Racial Disparities
- NTEU: IRS’s Push to Hire 3,700 Auditors Is Doable but Difficult
- IRS Floats Adding Partnerships to Prefiling Compliance Program
- IRS Hopes to Sic 3,700 New Revenue Agents on Big Businesses
- IRS Halts ERC Claims Processing Amid ‘Tsunami’ of Fraud
Follow us on Twitter:
- Jonathan Curry: @jtcurry005
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
*This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxstrategies23.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Garrett Brodeur, a tax attorney based in Washington, D.C., discusses the recently released proposed regulations for the cryptocurrency industry and their potential effect on digital asset transactions.
For additional coverage, read these articles in Tax Notes:
- Tax Pros Wary of Overly Inclusive Crypto Reporting Regs
- Decentralized Exchanges Considered Brokers Under Proposed Regs
- Proposed Regs Provide Guidance on Digital Asset Sales and Exchanges
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
*This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxstrategies23.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Tax Notes reporter Andrew Velarde discusses the latest developments on the final regulations for claiming foreign tax credits, including the IRS’s decision to delay implementation and the tax community’s response.
For more on the foreign tax credits, listen to "The Final Foreign Tax Credit Rules: Complaints and Confusion."
For additional coverage, read these articles in Tax Notes:
- IRS Says It Anticipates Extending FTC Relief Notice Another Year
- Treasury to Publish FTC Guidance on Pillar 2 Taxes by Year-End
- GOP Taxwriters to Air Grievances to OECD Leaders in Europe
- Silicon Valley Asks IRS to Extend Foreign Tax Credit Relief
- Johnson & Johnson Sees $500 Million Tax Benefit From FTC Reg Delay
- IRS Offers Temporary Relief From Foreign Tax Credit Rules
In our “Editors’ Corner” segment, Christopher Moran, counsel at Venable LLP in Baltimore, chats about his coauthored Tax Notes piece, “Proposed Energy Credit Regulations Limit Clean Energy Investment.”
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
*This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxstrategies23.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Professor Clint Wallace of the University of South Carolina School of Law discusses his argument for using tax policy to reinforce democracy.
For more, read Wallace's article, "A Democratic Perspective on Tax Law."
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
*This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxstrategies23.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Tax Notes Capitol Hill reporters Cady Stanton and Doug Sword preview what to expect from Congress in tax policy this fall, from a potential end-of-year tax package to IRS funding.
For additional coverage, read these articles in Tax Notes:
- GOP Taxwriters to Air Grievances to OECD Leaders in Europe
- Once Upon a Time: Bipartisan Senate Group OK’d $40B for IRS
- State SALT Workarounds Cost Feds at Least $10 Billion Annually
- Democrats Drew Line in Sand for IRA Provisions but Left IRS Out
- Endgame for Tax Legislation Extra Murky as Budget Impasses Loom
- R&D Expensing Revamp Tops Wish List for Year-End Tax Talks
- One Year Later, IRA’s Clean Energy Credits Remain Unknown to Many
- GOP SALT Cap Plans Overwhelmingly Benefit Wealthy, Report Says
Follow us on Twitter:
- Cady Stanton: @cady_stanton
- Doug Sword: @doug_sword
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
*This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxstrategies23.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
John McGowan of HubSync discusses artificial intelligence and its role in the tax field.
For additional coverage, read these articles in Tax Notes:
- AI in the DOR: State Tax Departments Ponder Use of Artificial Intelligence
- IRS Working to Deploy AI Algorithms and Models
- AI Programs Not Reliable Enough Yet for Tax Work, Attorney Says
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Tax Notes contributing editor Ryan Finley provides an overview of amount B from pillar 1 of the OECD’s two-pillar corporate tax reform plan and discusses the fundamental dispute over it.
For additional coverage, read these articles in Tax Notes:
- Analysis: Scoping-Criteria Dispute Overshadows Amount B Progress
- Analysis: OECD Agreement on Amount B Tax Deal Remains Elusive
Follow us on Twitter:
- Ryan Finley: @ryanmfinley
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Tom Cullinan, a former IRS official now with Chamberlain Hrdlicka, discusses the basics of the employee retention credit, the recent rise in misleading promotions and fraudulent ERC claims, and the IRS’s response.
For additional coverage, read these articles in Tax Notes:
- Employee Retention Credit a ‘Great Concern’ for IRS, Werfel Says
- IRS May Face Constraints in Quest to Curb ERC Abuse
- W&M Panel Considers Amnesty for Fraudulent ERC Payments
- Werfel Drops Hint, Seeks Early End to Employee Retention Credit
- IRS Zeroes In on Erroneous Employee Retention Credit Claims
- IRS Hard Line on ERC Eligibility Earns Kudos From Tax Pros
- Payroll Companies Likely Contributing to Mistaken ERC Claims
In our “Editors’ Corner” segment, Naomita Yadav, a partner at Withers in San Francisco, chats about her Tax Notes piece, “Sparing No One: Cross-Border Taxation of Globally Mobile Individuals,” the second in a two-part series.
Follow us on Twitter:
- Caitlin Mullaney: @MullaneyWrites
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Tax Notes White House reporter Alexander Rifaat discusses the Biden administration’s economic plan called “Bidenomics” and its effect on tax.
For additional coverage, read these articles in Tax Notes:
- National Economic Council Touts Impact of Biden Tax Incentives
- Biden Extols the Virtues of ‘Bidenomics’
- Treasury Links Construction Surge to CHIPS and IRA Credits
Follow us on Twitter:
- Alex Rifaat: @alexrifaat
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Manal Corwin, the new director of the OECD's Centre for Tax Policy and Administration, discusses her vision for the organization and the latest updates on the inclusive framework and two-pillar project.
For additional coverage, read these articles in Tax Notes:
- Vietnam Proposes Global Minimum Tax Rules to Apply in 2024
- BIAC Calls for More Consultations on Global Minimum Tax Rules
- U.K. Adopts Accounting Standard Changes for Pillar 2 Tax Rules
- Beyond the Numbers: Another Look at the JCT Pillar 2 Report
- Digital Taxes Won’t Go Away Anytime Soon, U.N. Official Says
- Autonomous Business Activities Exempt From OECD Amount A Tax Rules
- OECD Seeks Simpler Transfer Pricing With Amount B Consultation
- Countries Advance Pillar 1 Adoption, Extend Digital Tax Freeze
Follow us on Twitter:
- Stephanie Soong: @StephanieSoong
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Professor Hank Adler of Chapman University discusses the income realization requirement dispute in the transition tax case Moore v. United States before the Supreme Court, and its implications on the U.S. tax system.
For additional coverage, read these articles in Tax Notes:
- News Analysis: Limiting the Fallout From Moore
- Supreme Court to Hear Transition Tax Case With Vast Implications
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Marna Ricker, EY’s global vice chair of tax, discusses how international tax advisers and corporate tax clients have handled recent tax reforms and what to expect next.
For additional coverage, read these articles in Tax Notes:
- Extended OECD Digital Tax Ban Will Hurt Canada, Freeland Says
- Countries Advance Pillar 1 Adoption, Extend Digital Tax Freeze
- European Tech Companies Push for EU Action on Digital Taxes
- Australia Mulls More Pillar 2 Deferred Tax Break Disclosure Rules
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Professors Kathleen Delaney Thomas and Erin Scharff discuss fake tax news and the effect it has on public policy.
For more, read the professors' article "Fake News and the Tax Law."
Follow us on Twitter:
- Robert Goulder: @RobertGoulder
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Tax Notes reporters Cady Stanton and Michael Smith discuss the recently passed U.S.-Chile tax treaty and the importance of tax treaties on both a national and international scale.
For additional coverage, read these articles in Tax Notes:
- Chile-U.S. Tax Treaty Gets Senate Approval, Heads to White House
- Senate Scheduled to Vote on Chile-U.S. Tax Treaty
- Treasury's Treaty Approach Seeks to Avoid Future Complications
In our “Editors’ Corner” segment, George Jackson, a professor of management, business, and economics at Virginia Wesleyan University, chats about his Tax Notes piece, “Early History of the Deduction for Interest Paid.”
Follow us on Twitter:
- Cady Stanton: @Cady_Stanton
- Michael Smith: @TaxesMichael
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Steve Rosenthal of the Urban-Brookings Tax Policy Center reviews the GOP tax package approved by the House Ways and Means Committee, specifically the proposed individual and business tax cuts.
For additional coverage, read these articles in Tax Notes:
- House Tax Bill Racing Toward Floor Vote but Has a SALT Problem
- Ways and Means GOP Votes to Advance Tax Package
- GOP Introduces Tax Package to Kick Off Tax Bill Negotiations
- House Tax Bill to Focus on TCJA Extensions
Follow us on Twitter:
- Cady Stanton: @cady_stanton
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Scott Peterson of Avalara discusses the South Dakota v. Wayfair decision, including how companies and states are faring five years later and what could be next with sales tax nexus.
For additional coverage, read these articles in Tax Notes:
- Quad Graphics Urges Supreme Court to Take Up Sales Tax Appeal
- South Dakota’s Deb Peters Discusses Wayfair Five Years Later
- No Need to Hear Sales Tax Dispute, North Carolina Tells SCOTUS
- Halstead Bead Asks Fifth Circuit for Relief From Louisiana's Tax System
- North Carolina Institute Urges SCOTUS to Hear Sales Tax Dispute
- Arizona Lawmakers Consider Sales Tax Simplification Bill
- Panelists: Post-Wayfair Nexus Thresholds, Retroactive Application Still Unresolved
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Tax Notes reporter Alexander Rifaat discusses the tax implications of the recently passed debt ceiling bill and gentleman’s agreement over IRS funding.
For additional coverage, read these articles in Tax Notes:
- Biden Signs Debt Ceiling Bill Into Law
- Senate Approves Debt Limit Deal, IRS Clawbacks
- Freedom Caucus Voices Opposition to Debt Ceiling Agreement
Follow us on Twitter:
- Alex Rifaat: @alexrifaat
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Tax Analysts’ chief economist Martin Sullivan provides an overview of the state of the economy and how the recent debt limit bill could affect it.
For additional coverage, read these articles in Tax Notes:
- House Sends Debt Limit Bill, IRS Cuts to Senate
- Did the Pandemic Help or Hurt the Economy?
Follow us on Twitter:
- Marty Sullivan: @M_SullivanTax
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Former IRS Commissioner David Kautter, now with RSM, discusses the recently released report on the feasibility of an IRS-run direct file program.
For additional coverage, read these articles in Tax Notes:
- Free Direct-File Pilot Will Launch Next Year, IRS Says
- Report of Free File Prototype Irks Top Senate Finance Republican
- Use of Free File Service Dropped This Filing Season, TIGTA Finds
- Will Free File Alliance Survive Competition From the IRS?
Follow us on Twitter:
- Jonathan Curry: @jtcurry005
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Tax Notes reporter Andrea Muse provides an update on the state and federal lawsuits challenging Maryland’s digital advertising tax.
Listen to our previous episodes on this:
- The Fight Over Maryland’s Digital Advertising Tax, Part 1
- The Fight Over Maryland’s Digital Advertising Tax, Part 2
For additional coverage, read these articles in Tax Notes:
- Maryland High Court Hands State Victory in Digital Ad Tax Suit
- Maryland High Court Focuses on Exhaustion of Remedies in Digital Ad Tax Suit
- Maryland Urges State High Court to Uphold Digital Ad Tax
- Comcast, Verizon Respond to Professors in Maryland Digital Ad Tax Suit
- Digital Ad Tax Unconstitutional, Companies Tell Maryland Supreme Court
- Fourth Circuit Urged to Allow Federal Digital Ad Tax Suit to Proceed
- Maryland Urges Fourth Circuit to Reject Digital Ad Tax Suit
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Professors Bridget Crawford and Victoria Haneman discuss the estate and gift tax and how it could apply to the gifts received by Supreme Court Justice Clarence Thomas.
For additional coverage, read these articles in Tax Notes:
- Harlan Crow Dodges Wyden Request for Details on Thomas Gifts
- Wyden May Pursue Harlan Crow’s Tax Records
- Wyden Asks Harlan Crow for Details of Gifts to Thomas
In our “Editors’ Corner” segment, Ellen Aprill, the John E. Anderson Professor of Tax Law Emerita at Loyola Marymount University’s Loyola Law School, chats about her Tax Notes piece, “Reviewing For-Profit Philanthropy and the 1969 Tax Reform Act.”
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Tax Notes reporter Andrew Velarde discusses the penalty dispute in Farhy v. Commissioner and the case’s implications for other penalties and future refund decisions.
For additional coverage, read these articles in Tax Notes:
- In Farhy’s Wake, Taxpayer Advocate Renews Call for Penalty Change
- Fallout From Farhy on Assessable Penalties Could Be Extensive
- IRS Lacks Assessment Authority for Information Return Penalties
- Information Return Penalty Assessment Controversy Still Swirls
- Information Return Penalty Assessment Fight Coming to a Head
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Professor Kathleen Claussen of Georgetown Law discusses how the proposed regs for the new clean vehicle tax credit affect the EU and other countries without a free trade agreement.
For additional coverage, read these articles in Tax Notes:
- Volkswagen EV Gains Tax Credit Eligibility
- Treasury Balancing Act on EV Tax Credits Leaves Open Questions
- Taxwriters Criticize Trade Rep on EV Tax Credit Transparency
- EU and U.S. Draw Closer to Energy Tax Credit Deal
- EU Steps Up Its Efforts to Match U.S. Inflation Reduction Act
Follow us on Twitter:
- Sarah Paez: @PaezWrites
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Professor Samuel Brunson of Loyola University Chicago discusses social media tax scams highlighted in the IRS’s 2023 “Dirty Dozen” list of scams and how to spot this misinformation.
For more, read "Be Wary of Tax Advice on Social Media, IRS Warns," in Tax Notes.
In our “Editors’ Corner” segment, Robert van Brederode, the founding partner of BrederodeTax LLC, chats about his Tax Notes piece, “Disclosure of Presidential Tax Returns Violates Right to Privacy.”
Follow us on Twitter:
- Cady Stanton: @cady_stanton
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxplanning23.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Former IRS Commissioner Fred Goldberg, now with Skadden, shares his thoughts on the IRS’s strategies and proposals outlined in the recently released spending plan for the $80 billion granted by the Inflation Reduction Act.
For additional coverage, read these articles in Tax Notes:
- Werfel to Address IRS Budget and Filing Season at Senate Hearing
- Scholar Suggests Reforming IRS Over Spending More on Enforcement
- Foreign Taxpayers Cautiously Optimistic About IRS’s Payment Plan
- Everybody Wins Under IRS’s New Compliance Model, Observers Say
- Long-Awaited IRS Spending Plan Still Lacks Key Details
- IRS Spending Plan Puts Emphasis on Centralizing Activities
- Analysis: Transforming How the IRS Serves Taxpayers
Follow us on Twitter:
- Jonathan Curry: @jtcurry005
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxplanning23.
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax/events.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Tax Notes contributing editor Robert Goulder discusses the history of bank secrecy, Credit Suisse’s role in it, and the bank’s recent collapse.
For additional coverage, read these articles in Tax Notes:
- Government Goes After ‘Bank Hopping’ Couple for FBAR Penalties
- Finance Committee Says Hidden Swiss Bank Accounts Fight Isn't Over
- UBS May Have Bought Credit Suisse’s Undeclared Account Troubles
- FATCA Shortfalls Bring Calls for Elimination, Better Enforcement
- France Again Denies UBS Whistleblower’s Compensation Request
- Report: U.K. Residents Have £570 Billion Stashed in Tax Havens
Follow us on Twitter:
- Robert Goulder: @RobertGoulder
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxplanning23.
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax/events.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Tax Notes legal reporter Caitlin Mullaney discusses ChatGPT’s understanding of tax.
For more, read "Off the Beaten Tax: Could the Robots Be Coming for the Tax Preparers?" in Tax Notes.
Follow us on Twitter:
- Caitlin Mullaney: @MullaneyWrites
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax/events.
This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxplanning23.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Grace Perez-Navarro discusses her long career at the OECD Centre for Tax Policy and Administration and what’s next after her retirement.
For additional coverage, read these articles in Tax Notes:
- Analysis: The OECD’s Push for Women Leaders in Tax Transparency
- Analysis: Grace Perez-Navarro — A Champion of Transparency and Inclusion
Follow us on Twitter:
- Stephanie Soong: @StephanieSoong
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax/events.
This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxplanning23.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Kyle Pomerleau of the American Enterprise Institute discusses the Biden administration’s fiscal 2024 budget and examines how the tax proposals play into the administration’s wider political agenda.
For additional coverage, read these articles in Tax Notes:
- White House Budget Plan Targets Wealthy With Tax Increases
- Treasury Green Book Shows Few Major Changes in Tax Policy Goals
- Biden Budget Would Raise Taxes on Wealthy to Save Medicare
In our “Editors’ Corner” segment, Amish Shah, a partner at Holland & Knight, chats about his upcoming Tax Notes column on the intersection of clean energy and tax.
Follow us on Twitter:
- Alex Rifaat: @alexrifaat
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxplanning23.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart
Tax Notes contributing editor Nana Ama Sarfo discusses digital services taxes and the OECD’s goal to solve related challenges through the pillar 1 multilateral convention.
For additional coverage, read these articles in Tax Notes:
- Pillar 1 Tax Convention Talks Hitting Roadblocks, Le Maire Says
- DSTs, Destabilization, and the Rocky Road to Pillar 1
- Netflix Tells OECD to Mull Cultural Levies for DST Rollback List
- Kenya Urges Narrower DST Removal Scope for Wider Tax Deal Buy-In
- OECD Consults on DST Rollback, Global Minimum Tax Implementation
- U.K. Will Consider Extending DST if Pillar 1 Is Delayed
Follow us on Twitter:
- Nana Ama Sarfo: @nanaama_sarfo
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxplanning23.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Tony Santiago of TaxSearch Inc. discusses how the tax profession is changing and offers advice on developing future tax leaders.
For additional coverage, read Santiago's articles in Tax Notes:
- Addressing the Upcoming Tax Leadership Shortfall
- Prepare for the Biggest Tax Leadership Turnover Ever
- How an EY Split-Off Could Affect the U.S. Tax Profession
- Top Seven Reasons a Future Tax Leader Should Work in the Office
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxplanning23.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Tax Notes contributing editor Ryan Finley discusses the IRS’s major win in 3M and how it may affect other transfer pricing cases.
Listen to related episodes:
- Transfer Pricing Litigation Update II
- Transfer Pricing Litigation Update
- Coca-Cola Transfer Pricing Challenge Fizzles
For additional coverage, read these articles in Tax Notes:
- Analysis: 3M and the Renaissance of the Commensurate With Income Standard
- Supplemental Briefing Requested in Coca-Cola Transfer Pricing Case
- Tax Court Rejects 3M’s Challenge of Blocked Income Regs
- Analysis: Brazilian Transfer Pricing Reforms Ease U.S. Tax Frictions
Follow us on Twitter:
- Ryan Finley: @ryanmfinley
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Tax Notes legal reporter Nathan Richman talks with IRS Criminal Investigation Deputy Chief Guy Ficco about the upcoming Advance Collaboration Data Center and other CI initiatives.
For additional coverage, read these articles in Tax Notes:
- IRS Starts Showing Tax Fraud Fruits of Pandemic Investigations
- First Update to IRS’s Bank Secrecy Act Data Analysis Coming Soon
- IRS Criminal Investigators Want to Keep Talking About Bank Data
- IRS Looking for Real Tax Crime in Virtual Reality
- IRS Teams Collaborating to Thwart Emerging Cybercrimes and Fraud
- CI Chief Has a Big Plan for How to Find Tax Dirty Deeds
In our “Editors’ Corner” segment, Sharon Katz-Pearlman, a shareholder with Greenberg Traurig’s global tax practice in New York, chats about her Tax Notes piece, "Definitely Not Boring: The U.N. Tax Committee and OECD Collide.”
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Professor Steven Dean of Brooklyn Law School discusses the U.S. Treasury’s Equity Action Plan and its progress on examining potential racial bias in the tax code.
For additional coverage, read these articles in Tax Notes:
- Yellen Insists New Tax Credits Will Reduce Inequality
- Jury Is Still Out on Treasury Equity Plan
Listen to more Tax Notes Talk episodes from our critical tax theory series:
- Is IRS Tax Enforcement Colorblind?
- State Tax Authority and Native Americans: Complex and Convoluted
- Wealth, Inequality, and Taxes in the U.S.
- Feminism and the Tax Code
- Taxes and the LGBTQ Community
- Addressing Racial Inequity in State and Local Tax Policy
- The Tax Code and Economic Justice in America
- How Racial Diversity Shaped U.S. International Tax Policy
Follow us on Twitter:
- Alex Rifaat: @alexrifaat
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Tax Notes reporters Sarah Paez and Kiarra Strocko discuss what they found in an exploration of the OECD-supported mediation process for multinational corporations.
For more, read Paez and Strocko's article in Tax Notes, "OECD Corporate Mediation Lacks Teeth on Tax Matters, Critics Say."
In our “Editors’ Corner” segment, Abraham Leitner, a director at Goulston & Storrs PC, chats about his coauthored Tax Notes piece, " Reexamining Underwater Lease Assumption Transactions.”
Follow us on Twitter:
- Sarah Paez: @PaezWrites
- Kiarra Strocko: @KiarraStrocko
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Tax Notes Capitol Hill reporter Doug Sword discusses the latest national sales tax proposal in Congress, andcontributing editor Robert Goulder shares his thoughts on the challenges of implementing the tax.
For additional coverage, read these articles in Tax Notes:
- Perspective: The Orgy of Nontaxation
- Biden Criticizes Republican Plans to Abolish IRS
- Conservatives Say McCarthy Is Committed to National Sales Tax Vote
Follow us on Twitter:
- Doug Sword: @doug_sword
- Robert Goulder: @RobertGoulder
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
This episode is sponsored by 360 Coverage Pros. For more information, visit 360coveragepros.com/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Professor Diane Kemker of DePaul College of Law shares her argument for more coverage of the earned income tax credit in tax law casebooks to improve inclusivity.
For more, read Kemker's article "'Cracking Open' the Tax Casebook: Genre, Ideological Closure, and the Earned Income Tax Credit."
Follow us on Twitter:
- Caitlin Mullaney: @MullaneyWrites
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the District of Columbia Bar Taxation Community. For more information, visit https://site.pheedloop.com/event/TaxConference2023/home/?utm_source=TaxNotes&utm_medium=Banner&utm_campaign=TaxConference&utm_id=TaxConference.
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
This episode is sponsored by 360 Coverage Pros. For more information, visit 360coveragepros.com/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Tax Notes contributing editor Joseph J. Thorndike discusses the release of former President Trump’s tax returns and how they may influence the discourse around disclosure in the next presidential election.
To see the collection of presidential tax returns, visit taxnotes.com/tax-history-project.
For additional coverage, read these articles in Tax Notes:
- Watchdog Calls for TIGTA Inquiry Into IRS Trump Audits
- Nearly 6,000 Pages of Trump Returns Released, but Not IRS Files
- Trump and His Tax Returns Likely Fodder for Next Congress
- JCT: Audit of Trump Returns Relied on Accuracy of Paid Preparers
- Ways and Means Votes to Release Trump Tax Information
Follow us on Twitter:
- Joe Thorndike: @jthorndike
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the District of Columbia Bar Taxation Community. For more information, visit https://site.pheedloop.com/event/TaxConference2023/home/?utm_source=TaxNotes&utm_medium=Banner&utm_campaign=TaxConference&utm_id=TaxConference.
This episode is sponsored by the Tax Attorney Recruiting Event. For more information, visit the-tare.com.
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Tax Analysts Chief Content Officer Jeremy Scott reviews the 2022 developments in U.S. tax legislation and speculates about what may lie ahead.
For additional coverage, read these articles in Tax Notes:
- Nearly 6,000 Pages of Trump Returns Released, but Not IRS Files
- EV Credit Guidance Buys Time for Automakers on Battery Rules
- Initial Guidance Limits Buyback Tax on M&A Deals to Boot
- Corporate AMT Guidance Provides Safe Harbor and Some Relief
- A Look Ahead: After Policy Wins, White House Focus Turns to Implementation
- Federal Tax Changes May Continue to Affect States
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the District of Columbia Bar Taxation Community. For more information, visit https://site.pheedloop.com/event/TaxConference2023/home/?utm_source=TaxNotes&utm_medium=Banner&utm_campaign=TaxConference&utm_id=TaxConference.
This episode is sponsored by the Tax Attorney Recruiting Event. For more information, visit the-tare.com.
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.
Valerie Dickerson of Deloitte Tax LLP discusses key developments in state tax policy from 2022 that will likely remain relevant in 2023, including new incentives from the CHIPS Act.
For additional coverage, read these articles in Tax Notes:
- Louisiana Adopts Rules on Passthrough Entity Tax, NOLs
- Colorado Offers Millions in Incentives for Semiconductor Manufacturing Company
- Iowa DOR Proposes Required Composite Returns for Passthrough Entities
- Through the Looking Back: NYU Panelists Flag Multistate Issues for Year Ahead
- Oregon Business Interests to Seek Tax Incentives in 2023
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by SafeSend. For more information, visit safesend.com.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.
Tax Notes reporters recap some of the weirder stories they encountered in 2022, from the tax troubles of reality stars to a fight over a rather large tax bill for Christmas trees.
For additional coverage, read these articles in Tax Notes:
- Tax Crime Roundup: Reality TV Stars Face Real Prison
- Colorado Now Accepts Cryptocurrency for Tax Payments
- HMRC Under Fire for VAT Bill on S’mores Marshmallows
Listen to other tax oddities episodes:
- Year-End Collection: Tax Oddities of 2021
- Year-End Collection: Tax Oddities of 2020
Follow us on Twitter:
- Emily Hollingsworth: @EmilyHoll9
- Kiarra Strocko: @KiarraStrocko
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by SafeSend. For more information, visit safesend.com.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.
In the third of a three-episode series, former senior Treasury official Chip Harter discusses his experience creating the international tax guidance for the Tax Cuts and Jobs Act and the evolution of those provisions.
Listen to the other two episodes in the series:
- The TCJA Five Years Later: State Tax Issues
- The TCJA Five Years Later: Federal Tax Issues
For additional coverage, read these articles in Tax Notes:
- Proposed Regs Target Consolidated Group CFC Income Inclusions
- Anti-Injunction Act Bars Silver’s GILTI Suit, Court Finds
- Government Pursues Liberty Global for $284 Million in DRD Dispute
- Spectrum Brands Files Protective Return After Liberty Global
- Biden Wants to Drop the BEAT and Replace It With Pillar 2
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the District of Columbia Bar Taxation Community. For more information, visit https://site.pheedloop.com/event/TaxConference2023/home/?utm_source=TaxNotes&utm_medium=Banner&utm_campaign=TaxConference&utm_id=TaxConference.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.
In the second of a three-episode series, Jennifer Acuña, now with KPMG and former tax counsel for the Ways and Means Committee, discusses how guidance for the Tax Cuts and Jobs Act is still evolving.
Listen to the first episode in the series here: The TCJA Five Years Later: State Tax Issues
For additional coverage, read these articles in Tax Notes:
- This Isn’t Your Father’s Tax Extender Package
- Year-End Tax Title Still in Rumor Realm
- Dems Ready to Deal; GOP Is a ‘Maybe,’ Former Top Pelosi Aide Says
- Lame-Duck Talks May Be Stalled Through December 6
- Lack of GOP Wave Dims Section 199A Permanence Chances, Group Says
- Research Amortization Procedural Guidance Expected This Year
In our “Editors’ Corner” segment, Michelle Markham, a professor at Bond University, chats about her Tax Notes column, Markham on Managing Disputes, and her latest installment, “Advancing Tax Certainty: The New OECD Bilateral APA Manual.”
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by SafeSend. For more information, visit safesend.com.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.
In the first of a three-episode series, Steven Wlodychak, formerly with EY, discusses the creation of the SALT cap deduction by the Tax Cuts and Jobs Act and how states addressed it and other changes.
For additional coverage, read these articles in Tax Notes:
- Consistent Guidance on SALT Cap Workarounds Needed, Panel Says
- California Governor Signs SALT Cap Workaround Fix
- Pennsylvania Bill Would Create SALT Cap Workaround
- ‘No SALT, No Deal’ Becomes No More
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by the Tax Attorney Recruiting Event. For more information, visit the-tare.com.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.
Tax Notes chief correspondent Stephanie Soong discusses how countries are approaching implementation of the OECD’s two-pillar corporate tax reform plan and the future of the OECD after Pascal Saint-Amans’s departure.
Listen to more podcast episodes on the OECD's tax reform plan:
- Implementation Issues: An OECD Tax Reform Project Update
- The End Is Nigh: An Update on the OECD Tax Reform Plan
- The Beginning of the End? An Update on the OECD Tax Reform Plan
For additional coverage, read these articles in Tax Notes:
- ECOFIN To Soon Try Again for Global Minimum Tax Agreement
- Indian Barrister Calls for Global Indirect Tax Treaty
- OECD Seeks to Improve CbC Reporting Standard
- U.K. Treasury Confirms Plan to Implement Pillar 2
- G-20 Heads Urge Countries to Finish Work on Pillar 1 Tax Rules
- Global Tax Deal Could Change Views on CCTB, EU Official Says
In our “Editors’ Corner” segment, Naomita Yadav, a partner at Withers in San Francisco, chats about her Tax Notes column, (Tax) Matters of Life and Death, and her latest installment, “To PTE or Not to PTE: Estate Planning and SALT PTE Elections.”
Follow us on Twitter:
- Stephanie Soong: @StephanieSoong
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.
Stephanie Hunter McMahon of the University of Cincinnati College of Law discusses why labor performed by incarcerated workers should be subject to tax.
For more, read Hunter McMahon's article in Tax Notes, "Prison Work Is Taxing and Should Be Taxed."
Follow us on Twitter:
- Joe Thorndike: @jthorndike
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by 360 Coverage Pros. For more information, visit 360coveragepros.com/taxnotes.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.
In the second of a two-episode series, Orly Mazur of SMU Dedman School of Law discusses her views on the tax implications of increasing automation and the alternatives to a robot tax.
Listen to the first episode in this series, "Should We Have a Robot Tax? Part 2."
For more on Orly, read "A Conversation With Orly Mazur: Taking on Tax and Tech."
Follow us on Twitter:
- Marie Sapirie: @mariesapirie
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the Tax Attorney Recruiting Event. For more information, visit the-tare.com.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.
In the first of a two-episode series, Ryan Abbott of the University of Surrey discusses his views on the tax implications of increasing automation and the need for a robot tax.
For more, read Abbott and Bogenschneider's article, "Should Robots Pay Taxes? Tax Policy in the Age of Automation."
In our “Editors’ Corner” segment, Elizabeth Stevens, a member in the international tax practice at Caplin & Drysdale Chtd. in Washington, chats about her coauthored Tax Notes piece, “Transfer Pricing's Next Generation.”
Follow us on Twitter:
- Marie Sapirie: @mariesapirie
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the Tax Attorney Recruiting Event. For more information, visit the-tare.com.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.
Former IRS Commissioner Mark Everson, now with AlliantGroup, discusses the need to identify the agency’s next leader and how the IRS should use its additional funding from the Inflation Reduction Act.
For additional coverage, read these articles in Tax Notes:
- TIGTA Tees Up Hot-Button Issues for Review in 2023
- Leaderless IRS Threatens Credibility Crisis in Key Months Ahead
- Republicans Voice Concerns to GAO on IRS Funding Oversight
- Former Officials: Success of IRS Funding Boost Is at ‘Serious Risk’
- Ex-IRS Official Predicts Rapid Benefits From IT Upgrades
- Senate GOP Frets Over ‘Largely Unbridled’ IRS Funding
Follow us on Twitter:
- Jonathan Curry: @jtcurry005
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by 360 Coverage Pros. For more information, visit 360coveragepros.com/taxnotes.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.
U.S. Tax Court Chief Judge Kathleen Kerrigan discusses the court’s post-COVID transition and case management system, and how the additional funding from the Inflation Reduction Act may be used.
Listen to our episode with Judge Foley, "Talking With the Tax Court Chief Judge: A Year of Change."
For additional coverage, read these articles in Tax Notes:
- Company Looks to Reverse Tax Court Software Fee Deduction Ruling
- Medtronic II’s Unspecified Method Raises Specific Questions
- Tax Court Should Never Have Heard Whistleblower Case, IRS Says
- Tax Court’s Sealed Case Iceberg Will Soon Be Fully Thawed
In our “Editors’ Corner” segment, Filippo Noseda, a partner at Mishcon de Reya LLP and a visiting professor at King’s College in London, chats about his Tax Notes series on potentially corrupt behavior with FATCA and EU public registers.
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by 360 Coverage Pros. For more information, visit 360coveragepros.com/taxnotes.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.
It’s Tax Notes Talk’s fifth anniversary! Host David Stewart discusses the history of the podcast with current and former members of the team: Gulnar Zaman, Derek Squires, Paige Jones, and Jordan Parrish.
We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.
Follow us on Twitter:
- Gulnar Zaman: @zgulnar
- Paige Jones: @paigeleejones
- Jordan Parrish: @JoParrish96
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by 360 Coverage Pros. For more information, visit 360coveragepros.com/taxnotes.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Dan Neidle of Tax Policy Associates in London discusses the United Kingdom’s recent mini-budget and what effects the new tax proposals may have.
For additional coverage, read these articles in Tax Notes:
- Cutting Taxes Is ‘the Right Thing to Do,’ Truss Says
- Kwarteng Forced Into ‘Screeching U-Turn’ on Income Tax Rates
- Kwarteng to Bring Forward Medium-Term Fiscal Plan
- Kwarteng Criticized Over Delayed Publication of OBR Forecast
- U.K. Treasury Stands Firm Amid Criticism of Tax Measures
In our “Editors’ Corner” segment, Karl Frieden, vice president and general counsel of the Council On State Taxation, chats about his coauthored Tax Notes piece, “Down the Rabbit Hole: Sales Taxation of Digital Business Inputs.”
We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by 360 Coverage Pros. For more information, visit 360coveragepros.com/taxnotes.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Eric Solomon of Steptoe & Johnson LLP discusses the new excise tax on corporate stock buybacks and examines the issues that the IRS and Treasury will need to tackle before its implementation.
For additional coverage, read these articles in Tax Notes:
- IRS Officials Turn Attention and Increased Resources to IRA
- Lawmakers Indefinite on SPAC Buyback Tax Relief
- New Trouble Ahead for SPACs: The Stock Buyback Tax
- Buyback Tax May Alter Equity Compensation and Retirement Plans
We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.
Follow us on Twitter:
- Chandra Wallace: @ChandraSWallace
- David Stewart: @TaxStew
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**
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by 360 Coverage Pros. For more information, visit 360coveragepros.com/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Tax Notes contributing editor Ryan Finley discusses the latest updates in recent transfer pricing cases Eaton and Medtronic II.
Listen to related episodes:
- Transfer Pricing Litigation Update
- Coca-Cola Transfer Pricing Challenge Fizzles
For additional coverage, read these articles in Tax Notes:
- Analysis: Medtronic and the Role of Unspecified Transfer Pricing Methods
- Medtronic Might Trigger Up to $2 Billion Tax Liability
- Sixth Circuit Sides With Eaton in APA Cancellation Appeal
- Medtronic II’s Unspecified Method Raises Specific Questions
In our “Editors’ Corner” segment, Fernanda Kotzias, a counselor at the Brazilian Administrative Tax and Customs Court of Appeal, chats about her coauthored Tax Notes piece, “Brazil-U.S. Trade Agreement: A New Chapter for Trade Facilitation.”
We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.
Follow us on Twitter:
- Ryan Finley: @ryanmfinley
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by SafeSend. For more information, visit safesend.com.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Lauren Collins of Vinson & Elkins LLP provides an overview of the new tax credits designed to reduce greenhouse gas emissions in the Inflation Reduction Act.
Listen to our other episodes on the tax-related provisions in the Inflation Reduction Act:
- $80 Billion in New Funding: What’s Next for the IRS?
- Analyzing the Corporate Alternative Minimum Tax
For additional coverage, read these articles in Tax Notes:
- U.S. Is Lagging on Social Cost of Carbon, Study Says
- Lawmakers Seek Assistance for Clean Energy and EV Tax Credits
- Yellen to Promote New Tax Measures With Speaking Tour
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Robert Kerr of Kerr Consulting LLC discusses how the $80 billion of additional funding for the IRS in the Inflation Reduction Act could be best used by the agency.
For additional coverage, read these articles in Tax Notes:
- Backlog Thwarted IRS’s ‘Well-Planned’ IT Modernization Strategy
- IRS Urged to Budget for Transparency
- Yellen to Promote New Tax Measures With Speaking Tour
- Tax Professionals See Little to Fear in IRS Hiring Blitz
- CBO: IRS Funding Won’t Generate Much From Taxpayers Under $400K
In our “Editors’ Corner” segment, Sarah-Jane Morin, a partner with Morgan, Lewis & Bockius LLP, chats about her coauthored Tax Notes piece, “How the Definition of Digital Asset Brokers Was Brokered.”
We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.
Follow us on Twitter:
- Jonathan Curry: @jtcurry005
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Caroline Rule of Kostelanetz & Fink LLP discusses the post-Roe tax complications for employers covering abortion-related interstate travel expenses.
For more, read Rule's article, "Tax Implications of Dobbs for Interstate Travel Expenses to Obtain Abortions," in Tax Notes.
We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.
Follow us on Twitter:
- Caitlin Mullaney: @MullaneyWrites
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Professor Jeremy Bearer-Friend of the George Washington University Law School highlights key areas of the IRS’s tax enforcement where racial bias can occur.
For more, read Bearer-Friend's article, "Colorblind Tax Enforcement."
We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.
Listen to more Tax Notes Talk episodes from our critical tax theory series:
- State Tax Authority and Native Americans: Complex and Convoluted
- Wealth, Inequality, and Taxes in the U.S.
- Feminism and the Tax Code
- Taxes and the LGBTQ Community
- Addressing Racial Inequity in State and Local Tax Policy
- The Tax Code and Economic Justice in America
- How Racial Diversity Shaped U.S. International Tax Policy
Follow us on Twitter:
- Nana Ama Sarfo: @nanaama_sarfo
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by SafeSend. For more information, visit safesend.com.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Reuven Avi-Yonah of the University of Michigan Law School discusses the new corporate alternative minimum tax and how it intersects with international taxation.
For additional coverage, read these articles in Tax Notes:
- Inflation Reduction Act Raises Pillar 2 Hopes and Concerns
- Hard Part Begins for IRS and Treasury as Biden Signs Reconciliation Bill
- Critics Recall BURP in Debate Over Corporate Minimum Tax
We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Kyle Pomerleau of the American Enterprise Institute discusses the key tax provisions of the Inflation Reduction Act and what they mean for the future of tax policy.
For additional coverage, read these articles in Tax Notes:
- House Democrats Tee Up Tax Bill Debate and Nix GOP Amendments
- Critics Recall BURP in Debate Over Corporate Minimum Tax
- Democrats Play Whack-a-Mole as GOP Rages Against IRS Funding
- Partnership Rules Likely at Root of Corporate Minimum Tax Fight
- Biden and Democrats Relish Passage of Reconciliation Bill
We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
For more information and to download the Tax Advisory Industry Report, visit taxnotes.co/report.
For more information about the Tax Analysts Public Service Fellowship, visit our press release at taxnotes.com/fellowship.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Tax Notes reporter Benjamin Guggenheim discusses the latest tax legislation on Capitol Hill: the recently passed CHIPS and Science Act and the revived reconciliation bill known as the Inflation Reduction Act.
For additional coverage, read these articles in Tax Notes:
- Sinema Wants Carried Interest Out of Reconciliation, Reports Say
- Clawbacks Will Prevent Companies From Exporting CHIPS Benefits
- Ex-Treasury Secretaries Support Inflation Reduction Act
- Democrats Hit Back at Criticism of Inflation Reduction Act
- Reconciliation Tax Reform Limited by Delicate Negotiations
- Computer Chip Bill Passes House, Heads for Biden Signature
- Key Senators Reach Deal on Corporate Tax, Carried Interest
In our “Editors’ Corner” segment, John Craig, an associate in the Washington office of Gibson, Dunn & Crutcher LLP, chats about his coauthored Tax Notes piece, “The Appeals Access Saga Continues.”
We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.
Follow us on Twitter:
- Benjamin Guggenheim: @ben_guggenheim
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
For more information about the Tax Analysts Public Service Fellowship, visit our press release at taxnotes.com/fellowship.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Martin A. Sullivan, Tax Analysts’ chief economist, revisits the United States’ economic path to inflation and discusses mitigation efforts for a possible recession.
For more inflation coverage on the podcast, listen to Inflation, Tax, and the COVID-19 Economy.
For additional coverage, read these articles in Tax Notes:
- Grassley Follows Up With Second Inflation-Indexing Package
- North Carolina Republicans' Budget Preserves Income Tax Cuts
- California Budget Deal Includes Billions in Inflation Relief
We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.
Follow us on Twitter:
- Martin Sullivan: @M_SullivanTax
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by SafeSend. For more information, visit safesend.com.
For more information and to download the Tax Advisory Industry Report, visit taxnotes.co/report.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Tax Notes chief correspondent Stephanie Soong Johnston recaps the agreement on the OECD’s two-pillar corporate tax reform plan and discusses recent roadblocks to full implementation.
Listen to more podcast episodes on the OECD's tax reform plan:
- The End Is Nigh: An Update on the OECD Tax Reform Plan
- The Beginning of the End? An Update on the OECD Tax Reform Plan
- New Year, New Tax Rules? An OECD Tax Reform Project Update
For additional coverage, read these articles in Tax Notes:
- U.K. Moves to Implement OECD-Brokered Global Minimum Tax Rules
- G-20 Ministers Push Ahead on Global Tax Reform Amid U.S. Hurdles
- White House Downplays Global Tax Deal Concerns
- India Calls for Syncing Pillar 2 Treaty Rule and Amount B Rules
- OECD Fills in More Blanks on Amount A Draft Model Tax Rules
- Treasury to Nix Tax Treaty With Hungary for EU Minimum Tax Veto
- Support Rises for Circumventing Hungary on Pillar 2
- Hungarian Lawmakers Nix EU Pillar 2 Minimum Tax Directive
In our “In the Pages” segment, Heydon Wardell-Burrus, a researcher at the Oxford Centre for Business Taxation, chats about his Tax Notes piece, “Can Pillar 2 Be Leveraged to Save Pillar 1?”
We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.
Follow us on Twitter:
- Stephanie Soong Johnston: @SoongJohnston
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
For more information about the Tax Analysts Public Service Fellowship, visit our press release at taxnotes.com/fellowship.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Tax Notes reporter Jonathan Curry discusses the IRS audits of former FBI Director James Comey and his deputy, Andrew McCabe, and why they’ve drawn attention from the tax community.
For additional coverage, read these articles in Tax Notes:
- House and Senate Taxwriters to Quiz Rettig in Private Meetings
- Rettig Requests TIGTA Investigation of Comey, McCabe Audits
- Former IRS Officials Skeptical of Foul Play in Comey, McCabe Audits
We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.
Follow us on Twitter:
- Jonathan Curry: @jtcurry005
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
For more information and to download the Tax Advisory Industry Report, visit taxnotes.co/report.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Nicholas Mowbray of BakerHostetler discusses the recently enacted Superfund excise taxes on chemicals and hazardous substances and some compliance concerns and uncertainty surrounding them.
For additional coverage, read these articles in Tax Notes:
- IRS Releases New Environmental Taxes Form as Superfund Kicks In
- IRS Issues Rules on Requesting Superfund Substance List Changes
- IRS Releases Rates for Superfund Chemical Excise Tax
- IRS Issues Lengthy List of Substances to Face Superfund Tax
In our “In the Pages” segment, Nikki Dobay, a partner with Eversheds Sutherland (US), chats about her Tax Notes piece, “Cross-Border State Legislative Tax Wars: Is This Just the Beginning?”
We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.
Follow us on Twitter:
- Nana Ama Sarfo: @nanaama_sarfo
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by SafeSend. For more information, visit safesend.com.
For more information about the Tax Analysts Public Service Fellowship, visit our press release at taxnotes.com/fellowship.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
La Posada Tax Clinic Director Robert Wunderle discusses the importance of low-income taxpayer clinics to the tax system and how his clinic serves the Twin Falls, Idaho, community.
For more information about the Tax Analysts Public Service Fellowship, visit taxnotes.com/fellowship.
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by SafeSend. For more information, visit safesend.com.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Elaine Maag of the Urban-Brookings Tax Policy Center looks at lessons learned from the 2021 advance child tax credit and its potential political future.
Listen to our other episodes on the child tax credit:
- The Advance Child Tax Credit: Changes Coming?
- The Advance Child Tax Credit: What Lies Ahead
For additional coverage, read these articles in Tax Notes:
- Analysis: Resolving the Child Tax Credit Conundrum
- Boosted Child Credit Helped More Parents Feel Financially Secure
- GAO Suggests Tax Credits Contribute to Racial and Gender Disparities
- Inflation, Child Tax Credit Rollback Endanger Business Tax Breaks
In our “In the Pages” segment, Omri Marian, professor of law and academic director of the graduate tax program at the University of California, Irvine School of Law, chats about his Tax Notes piece, “Law, Policy, and the Taxation of Block Rewards.”
Follow us on Twitter:
- Marie Sapirie: @MarieSapirie
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
For more information about the Christopher E. Bergin Award for Excellence in Writing, visit taxnotes.com/students.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
For more information about the Tax Analysts Public Service Fellowship, visit our press release at taxnotes.com/fellowship.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Marie-France Dompierre of Davies Ward Phillips & Vineberg discusses how Canada taxes professional athletes who aren’t Canadian residents.
For more, read Dompierre's article, "An ‘Expensive’ Trade? Taxation of Nonresident Professional Athletes Playing in Canada," in Tax Notes.
For more episodes on taxes and sports, listen to:
- The NCAA vs. Taxation: How Colleges Are Caught in the Middle
- Taxing College Athletes After NCAA v. Alston
Follow us on Twitter:
- Stephanie Soong Johnston: @SoongJohnston
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
Tax Analysts is honored to be recognized by The Washington Post as a 2022 Top Workplace in the D.C. metro area. For more information, visit taxnotes.com/dc2022.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
For more information about the Christopher E. Bergin Award for Excellence in Writing, visit taxnotes.com/students.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Raymond Stahl of Ernst & Young discusses concerns about the final regulations for claiming foreign tax credits, particularly how they affect creditability, withholding, and treaty benefits.
For additional coverage, read these articles in Tax Notes:
- Yellen Nixes Foreign Tax Credit Reg Delay, Defends OECD Talks
- Treasury Offers More Details on FTC Royalty Withholding Carveout
- Valuation Allowances Soften FTC Regs' Blow for Some Taxpayers
- FTC Analysis Worries Persist in Regs, USCIB Warns U.S. Treasury
- Tax Treaties May Offer Relief From More Troublesome FTC Regs
- FTC Regs’ Attribution Requirement Raises Administrability Issues
In our “In the Pages” segment, Kathleen Wright, director of the state and local tax program in the School of Taxation at Golden Gate University, chats about her Tax Notes piece, “The States’ Response to Wynne Seven Years Later.”
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
For more information about the Christopher E. Bergin Award for Excellence in Writing, visit taxnotes.com/students.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
For more information about the Tax Analysts Public Service Fellowship, visit our press release at taxnotes.com/fellowship.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Johan Langerock, policy adviser in the European Parliament, discusses his visit to Washington, the future of the OECD two-pillar tax plan, and the EU’s green initiative.
For additional coverage, read these articles in Tax Notes:
- DSTs ‘Back on Table’ if U.S. Doesn’t Adopt Pillar 1, MEPs Say
- EU Stays Focused on Pillar 2 Despite Pillar 1 Delays
- Pressure Mounts for EU Ministers on Pillar 2 Agreement
- EU Lawmakers Back Climate Plans but Challenges Remain
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
For more information about the Christopher E. Bergin Award for Excellence in Writing, visit taxnotes.com/students.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Tax Notes reporter Benjamin Valdez discusses the Florida legislation eliminating Disney's special tax district, what led to its passage, and what to expect in the future.
For additional coverage, read these articles in Tax Notes:
- Federal Judge Dismisses Taxpayers' Suit Over Disney District Bill
- Florida Taxpayers Sue Over Disney Tax District Dissolution
- Florida Governor Signs Bill to End Disney's Special Tax District
- Florida Bill to Eliminate Disney’s Special Tax District Goes to Governor
- Florida Governor Seeks to End Disney’s Special Tax District
Follow us on Twitter:
- Benjamin Valdez: @benmvaldez
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
For more information about the Tax Analysts Public Service Fellowship, visit our press release at taxnotes.com/fellowship.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Tax Notes reporters Paul Jones and Nathan Richman discuss the $141 million settlement over Intuit’s TurboTax Free Edition program and the potential tax break for Intuit.
For additional coverage, read these articles in Tax Notes:
- TurboTax Settlement May Open the Door to Huge Tax Break
- Intuit, States Enter Settlement Over ‘Free File’ Scandal
- GAO: Taxpayer Use of Free File Waned After Intuit’s Exit
- Intuit’s Ad Campaign for ‘Free’ Tax Software Draws FTC Ire
- Intuit to Exit Free File Alliance
- Intuit Fails to Secure Injunction in Tax Prep 'Bait-and-Switch' Fight
- Intuit Free File Arbitration Strategy Backfires
- New York Governor Calls for Investigation of Tax Return Preparers
In our “In the Pages” segment, Allison Christians, the H. Heward Stikeman Chair in Tax Law at McGill University in Montreal, chats about her Tax Notes piece, “Let the GILTI/GLOBE Games Begin.”
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Elodie Lamer and Nana Ama Sarfo of Tax Notes discuss the tax implications of golden visas and passports, which allow affluent foreigners to receive residency or citizenship in exchange for a minimum level of investment.
For additional coverage, read these articles in Tax Notes:
- EU Commission Proposes Thorough Examinations of Golden Visas
- EU Commission Steps Up Legal Fight Over Maltese Golden Passports
- EU Commission Wants to Revoke Golden Passports of Putin Allies
- EU Considers Strengthening Security Checks of Golden Visa Holders
- Italy and NGOs Call for Open Wealth Registry to Target Russians
- Analysis: Tax Incentives Among the Lures Targeting Digital Nomads
- Vanuatu’s Golden Passport Regime Endangers Agreement With EU
- EU Greenlights Malta's Plans for Tackling Tax Avoidance
Follow us on Twitter:
- Elodie Lamer: @ElodieLamer
- Nana Ama Sarfo: @nanaama_sarfo
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
For more information about the Tax Analysts Public Service Fellowship, visit our press release at taxnotes.com/fellowship.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Timothy Noonan of Hodgson Russ LLP discusses how some states tax remote employees and the effect of temporary pandemic tax changes.
For additional coverage, read these articles in Tax Notes:
- Bill Seeks to Shield Teleworkers From St. Louis's Earnings Tax
- Analysis: The Pandemic’s Tax Fallout Continues
- Remote Work Complicates Employer Tax Compliance, Pressures States to Revise Rules
- New York Remote Work Rules Clash With COVID-19 Realities, Experts Say
In our “In the Pages” segment, Doug Borg, a manager in the Washington office of RSM US LLP, chats about his coauthored Tax Notes piece, “Puerto Rico Resident Exemption to Be Focus of IRS Audit Campaign.”
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Beth Viola and Nicole Elliott of Holland & Knight discuss the latest clean energy tax proposals and the likelihood of their passage in Congress.
For additional coverage, read these articles in Tax Notes:
- Bipartisan Energy Bill May Focus on Carbon Capture Credits
- Analysis: Low-Carbon Hydrogen Credits Break Through
- Green Tax Credits Spotlighted in State of the Union
Follow us on Twitter:
- Marie Sapirie: @mariesapirie
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by the District of Columbia Bar. For more information, visit dcbar.org.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Valeria Tarasenko of Dentons Kyiv discusses the Ukrainian government’s tax policy changes in response to the Russian invasion.
For additional coverage, read these articles in Tax Notes:
- Ukraine Issues Guidance on Corporate Tax Benefits
- Argentina Proposes Tax on Profits of Firms Benefiting From War
- ICRICT Calls on G-20 to Establish Global Asset Registry
- NGOs Highlight Effectiveness of Taxing Russian Energy
- Bipartisan Bill Targets Foreign Tax Credits in Russia
- Ukraine Considering Tax Increases for MNEs With Ties to Russia
- OECD Expects More Information Requests as War in Ukraine Rages
In our “In the Pages” segment, Robert van Brederode, the founding partner of BrederodeTax LLC, chats about his Tax Notes International article, “Ethical Equilibrium in Taxation.”
Follow us on Twitter:
- Sarah Paez: @PaezWrites
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.
This episode is sponsored by the District of Columbia Bar. For more information, visit dcbar.org.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
IRS Commissioner Charles Rettig discusses the current state of the tax agency, including the paper return backlog, technology improvements, and hiring updates.
Listen to the entire interview here: The State of the IRS with Commissioner Charles Rettig
For additional coverage, read these articles in Tax Notes:
- Rettig Warns Against New Info Reporting Rules Without Funding
- New Tax Credits Blamed for Huge Number of 2021 Filing Errors
- New Hiring Authority Paying Off for IRS, Rettig Says
- Taxpayer Advocate Urges Rapid IRS Uptake of Paper-Scanning Tech
- IRS Modernization Has Means but Not Funding, Rettig Says
- Rettig Makes a Big Backlog Pledge, Defends Audit Priorities
Follow us on Twitter:
- Cara Griffith: @TaxCaraGriffith
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
For more about the Christopher E. Bergin Award for Excellence in Writing, visit taxnotes.com/students.
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.
This episode is sponsored by the District of Columbia Bar. For more information, visit dcbar.org.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Rohit Kumar of PwC discusses the Biden administration’s fiscal 2023 budget, explaining the new proposals and how the budget is different than the Build Back Better Act.
For additional coverage, read these articles in Tax Notes:
- Tax Pros Eye Biden’s Estate Tax Plans, Shrug Off Billionaire’s Tax
- White House Seeks Double-Digit Increase in IRS Funding
- Plans for Taxing the Wealthy and Corporations Grow Larger
- Treasury Green Book Reveals Major Changes in Tax Goals
In our “In the Pages” segment, Tony Santiago, the founder and president of TaxSearch Inc., chats about his series on the hiring and retention of U.S. tax professionals. Read the first article in his series, “Tax Hiring Outlook 2022.”
Follow us on Twitter:
- Jonathan Curry: @jtcurry005
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.
This episode is sponsored by the District of Columbia Bar. For more information, visit dcbar.org.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Tax Notes reporters Jonathan Curry and Caitlin Mullaney set the record straight on 10 common tax myths.
For more coverage, read Mullaney's article in Tax Notes, "#TaxTok Answers the Request for Easy-to-Understand Tax Info."
Follow us on Twitter:
- Jonathan Curry: @jtcurry005
- Caitlin Mullaney: @MullaneyWrites
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
For more about the Christopher E. Bergin Award for Excellence in Writing, visit taxnotes.com/students.
**
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Marlene Nembhard Parker and Fabrizia Lapecorella discuss their partnership as the first co-chairs of the OECD inclusive framework on base erosion and profit shifting and speculate on the future of women leading international tax.
For additional coverage, read these articles in Tax Notes:
- OECD's BEPS Inclusive Framework Appoints New Co-Chair
- OECD Tax Standard-Setting Body Appoints New Chair
Follow us on Twitter:
- Stephanie Soong Johnston: @SoongJohnston
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the the American Bar Association Tax Section. For more information, visit ambar.org/taxnotes.
This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart
Tax Notes reporter Andrew Velarde discusses the tax structure dispute in Whirlpool v. Commissioner and the case’s future implications for multinational companies.
For additional coverage, read these articles in Tax Notes:
- No Full Court Rehearing for Whirlpool, Sixth Circuit Says
- Whirlpool Agitated Over Attempt to Brand It a Tax Cheat
- Parts Manufacturer Sees Daylight Between Itself and Whirlpool
- DOJ Urges Circuit to Reject Whirlpool’s Call for Rehearing
- Groups Line Up to Warn Circuit About Whirlpool Fallout
- Whirlpool Wants Circuit to Give Branch Income Case Another Spin
- Whirlpool’s Circuit Court Loss Could Cost It $95 Million
In our “In the Pages” segment, Gary Wilcox, a partner at Mayer Brown LLP, chats about his coauthored Tax Notes piece, “Will Jurisdictional Nexus Survive Chevron Step 1?”
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the the American Bar Association Tax Section. For more information, visit ambar.org/taxnotes.
This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Professor Richard Schmalbeck of Duke University Law School discusses college sports and taxation, including the potential effect of compensation for coaches and athletes on colleges’ tax-exempt status.
For more, read Schmalbeck and Zelenak's paper, "The NCAA and the IRS: Life at the Intersection of College Sports and the Federal Income Tax."
For related coverage, read these articles in Tax Notes:
- Taxwriter Questions More Universities About Coaches' Salaries
- Taxwriter Questions Big Salaries of Two College Coaches
Listen to the episode mentioned: Taxing College Athletes After NCAA v. Alston
Follow us on Twitter:
- Robert Goulder: @RobertGoulder
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the the American Bar Association Tax Section. For more information, visit ambar.org/taxnotes.
This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Martin A. Sullivan, Tax Analysts’ chief economist, provides an overview of the U.S. economy before and during the COVID-19 pandemic, explaining the drastic increase in inflation and what is needed to curb it.
For more, read Sullivan's article in Tax Notes, "Your Quick Guide to the COVID-19 Economy and the Future of Inflation."
Listen to the episodes mentioned in this interview:
- Breaking Down the American Rescue Plan Act
- Countering the Coming Coronavirus Recession
Follow us on Twitter:
- Martin Sullivan: @M_SullivanTax
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the the American Bar Association Tax Section. For more information, visit ambar.org/taxnotes.
This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Professor Adam Crepelle of the George Mason University Antonin Scalia Law School discusses the complicated tax relationship between U.S. states and Native American tribes.
Listen to more Tax Notes Talk episodes from our critical tax theory series:
- Wealth, Inequality, and Taxes in the U.S.
- Feminism and the Tax Code
- Taxes and the LGBTQ Community
- Addressing Racial Inequity in State and Local Tax Policy
- The Tax Code and Economic Justice in America
- How Racial Diversity Shaped U.S. International Tax Policy
In our “In the Pages” segment, Tatiana Falcão, an international tax law consultant and policy adviser, chats about her Tax Notes series on cryptocurrency.
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the the American Bar Association Tax Section. For more information, visit ambar.org/taxnotes.
This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Pascal Saint-Amans discusses his decadelong tenure as the director of the OECD Centre for Tax Policy and Administration and what’s to come in the future.
For additional coverage, read these articles in Tax Notes:
- A Decade of Change: OECD Tax Chief Looks Back at 10 Years on the Job
- OECD Working to Cut Revenue Sourcing Complexity, Tax Chief Says
- Uncoordinated Climate Policies Risk Carbon Leakage, OECD Warns
- Countries Must Unite on Carbon Pricing, OECD Tax Chief Says
- Conversations: Pascal Saint-Amans
Follow us on Twitter:
- Stephanie Soong Johnston: @SoongJohnston
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the the American Bar Association Tax Section. For more information, visit ambar.org/taxnotes.
This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Eelco van der Enden, the new CEO of the Global Reporting Initiative, discusses the growing environmental, social, and governance landscape and why tax is a necessary and important part of ESG reporting.
For more, read Sarfo's article on van der Enden, "New GRI CEO Shares Vision on ESG Tax Disclosures."
In our “In the Pages” segment, Steven Wlodychak, the former indirect state and local tax policy leader for EY, chats about his upcoming Tax Notes piece, “State PTE Tax Updates: Agency Guidance and Even More Differences!”
Follow us on Twitter:
- Nana Ama Sarfo: @nanaama_sarfo
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the the American Bar Association Tax Section. For more information, visit ambar.org/taxnotes.
This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Tax Notes reporter Jonathan Curry reviews President Biden’s tax policy campaign promises after one year in office and where those proposals, including the Build Back Better Act, stand today.
For additional coverage, read these articles in Tax Notes:
- Build Back Better Talks Reset, Without a Deadline This Time
- Manchin Calls Build Back Better ‘Dead’; Schumer Vows to Advance
- House and Senate Reconciliation Bills Differ on 24 Tax Provisions
- Hope Springs Eternal for Some of Biden’s Tax Priorities
- OECD Global Tax Deal a Testament to Multilateralism, Yellen Says
- Biden Backs Breaking Up Build Back Better Act
Follow us on Twitter:
- Jonathan Curry: @jtcurry005
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the the American Bar Association Tax Section. For more information, visit ambar.org/taxnotes.
This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Max Dilendorf of the Dilendorf Law Firm PLLC discusses non-fungible tokens, or NFTs, and the related tax planning and compliance issues.
In our “In the Pages” segment, Edward Zelinsky, Morris and Annie Trachman Professor of Law at the Benjamin N. Cardozo School of Law of Yeshiva University, chats about his recent Tax Notes piece, “Simplifying Income Tax Reporting for Americans Abroad.”
For additional coverage, read these articles in Tax Notes:
- More Cryptocurrency Reporting Changes May Be on the Horizon
- OECD Ponders Tax Implications of Non-Fungible Tokens
- NFT Markets Create More Tax Concerns Than Just Gains
- State Taxes and the Digital Economy: NFTs and the MTC Project
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the UC Irvine School of Law's Graduate Tax Program. For more information, visit the-tare.com.
This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.
This episode is sponsored by the the American Bar Association Tax Section. For more information, visit ambar.org/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Beverly Winstead of the Law Office of Beverly Winstead LLC and Paul Miller of Miller & Co. LLP discuss the 2022 filing season’s challenges and considerations in the third year of the pandemic.
For additional coverage, read these articles in Tax Notes:
- Ineligible Taxpayers May Be Able to Keep Child Tax Credits
- Lawmakers Report Surge in Requests for Help With Unresponsive IRS
- Congress May Consider Pausing Automated IRS Notices
- Taxpayer Advocate Report Prompts Concern, Emergency Funds Request
- Treasury and IRS Prepare for the Worst as Filing Season Looms
Follow us on Twitter:
- Marie Sapirie: @MarieSapirie
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the the American Bar Association Tax Section. For more information, visit ambar.org/taxnotes.
This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.
This episode is sponsored by the UC Irvine School of Law's Graduate Tax Program. For more information, visit the-tare.com.
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Will Morris, former chair of the tax committee at Business at OECD, reflects on his nearly decadelong tenure and experiences leading the business community through OECD global corporate tax reform projects.
Read Soong Johnston's profile on Morris: Changing of the Guard: Ex-BIAC Tax Chair Reflects on Tenure
Follow us on Twitter:
- Stephanie Soong Johnston: @SoongJohnston
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the UC Irvine School of Law's Graduate Tax Program. For more information, visit the-tare.com.
This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.
This episode is sponsored by the the American Bar Association Tax Section. For more information, visit ambar.org/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
In honor of Tax Notes Talk’s 200th episode, we review some of our favorite interviews and discussions from the last 100 episodes.
In our “In the Pages” segment, Andrew Hughes, a Brussels-based economist who specializes in transfer pricing, valuation, and risk management, chats about his Tax Notes series on transfer pricing.
Listen to our 100th episode: Tax Notes Goes To Court (Again)
Find out the answer to the tax trivia question by listening to The Category Is Tax Trivia.
Listen to the episodes mentioned:
- Wealth, Inequality, and Taxes in the U.S.
- Talking With the National Taxpayer Advocate: A Look Ahead
- The End Is Nigh: An Update on the OECD Tax Reform Plan
- Talking With Paul Tang: Tax Fairness in the EU
- How Tax Policy Can Help Low-Income Americans’ Pandemic Plight
- Talking With the Tax Court Chief Judge: A Year of Change
- 50 Years Later: The Fight for Tax Transparency
- The BEPS Project: 5 Years Later
- A Very Special Episode
- From Henry VIII to James Bond: Weird Tax Facts Throughout History
- The CARES Act: What's New and What's Next
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the the American Bar Association Tax Section. For more information, visit ambar.org/taxnotes.
This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.
This episode is sponsored by the UC Irvine School of Law's Graduate Tax Program. For more information, visit the-tare.com.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Tax Analysts Chief Content Officer Jeremy Scott reviews the 2021 developments in U.S. tax legislation and speculates what lies ahead in 2022.
For additional coverage, read these articles in Tax Notes:
- Schumer Vows Build Back Better Vote as Manchin, Dems Squabble
- Build Back Better Act Will Drag on Into New Year
- Child Credit Deadline Adds Pressure to Reconciliation Efforts
- Uncertainty Mars Future of Advance Child Credit Administration
- Republican Senators Eye Legislative Fix for Crypto Rules
- House Sends Infrastructure Bill to Biden, With Pledge to Do More
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the UC Irvine School of Law's Graduate Tax Program. For more information, visit the-tare.com.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Tax Notes reporters recap some of the unusual tax stories they covered in 2021, from an international basketball player’s tax troubles to a court fight in India over a Michael Jackson concert tax.
Listen to the following related podcast episodes:
- Year-End Collection: Tax Oddities of 2020
- Year-End Collection: Tax Oddities of 2019
- Year-End Collection, Volume 2: Tax Oddities
- Year-End Collection, Volume 1: Tax Oddities
For additional coverage, read these news articles in Tax Notes:
- Texas Senator: Curb Sports Team Incentives Over Mavericks' Anthem Dustup
- Ex-NBA Player Hit With Tax, Wire Fraud Charges for Chinese Play
- French Tax Authorities Can Use Social Media Data to Catch Fraud
- Beat It! Tax Waived on 1996 Michael Jackson Concert in Mumbai
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
- Robert Goulder: @RobertGoulder
- Sarah Paez: @PaezWrites
**
This episode is sponsored by the UC Irvine School of Law's Graduate Tax Program. For more information, visit the-tare.com.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Benjamin Alarie with Blue J Legal discusses how technology is influencing and changing the tax field and the future of tax jobs.
For the related episode mentioned in the intro, listen to Teaching Tomorrow’s Tax Pros.
For additional coverage, read these articles in Tax Notes:
- Business of Tax: AI Brings Uncertainty and Opportunity to Tax Practice
- Business of Tax: The Emergence of the High-Tech Accountant
- Business of Tax: Why Aren’t Accounting Firms Hiring Accountants?
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the UC Irvine School of Law's Graduate Tax Program. For more information, visit the-tare.com.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Adam Feinberg with Miller & Chevalier discusses air travel taxation, how it affects passengers, and the biggest issues for airlines.
In our “In the Pages” segment, Timothy Noonan, partner with Hodgson Russ, chats about his recent Tax Notes piece, "The Nuts and Bolts of New York’s 548-Day Rule, Revisited."
For additional coverage, read these articles in Tax Notes:
- Wisconsin Justices Affirm Denial of Property Tax Break for Airlines
- Georgia Moves to End Jet Fuel Tax Break After Delta Slams Voter Law
For a related episode, listen to Aviation Taxes: Ready For Takeoff.
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by the UC Irvine School of Law's Graduate Tax Program. For more information, visit the-tare.com.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Carl Davis of the Institute on Taxation and Economic Policy discusses the biggest trends in state tax policy this year and those likely next year, including the implications of the Build Back Better Act.
For additional coverage, read these articles in Tax Notes:
- Arkansas Taxwriters Float Plan to Cut Income Taxes
- Maryland AG: Digital Ad Tax Is Not a Penalty for TIA Purposes
- New Mexico Governor Proposes Sales Tax Cut
- Georgia House Panel Advances IRC Conformity Bill
- Texas, Washington Voters Weigh In on Tax Policy
- Ohio Pot Legalization, Taxation Effort Can Gather Signatures
- Existing Tax Rules May Already Serve Pot Tax Transition
For related episodes, listen to:
- The Fight Over Maryland’s Digital Advertising Tax, Part 1
- The Fight Over Maryland’s Digital Advertising Tax, Part 2
- The State Fight to Eliminate the Federal Restriction on Tax Cuts
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by the UC Irvine School of Law's Graduate Tax Program. For more information, visit the-tare.com.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Mike Kowis, author of American Tax Trivia: The Ultimate Quiz on U.S. Taxation, challenges the Tax Notes Talk team to a game of tax trivia and discusses his new book.
In a special “In the Pages” segment, Tax Notes International columnist Peter Mason chats about his new book, Building Better Taxes.
Listen to related episodes:
- Stranger Than Fiction: Lessons From Odd Tax Facts of Yore
- From Henry VIII to James Bond: Weird Tax Facts Throughout History
Follow us on Twitter:
- Robert Goulder: @RobertGoulder
- Stephanie Soong Johnston: @SoongJohnston
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
In the second of a two-episode series, Professor Richard D. Pomp of the University of Connecticut School of Law discusses his views on the federal lawsuit challenging Maryland’s digital advertising tax.
Listen to the first episode in the series: The Fight Over Maryland’s Digital Advertising Tax, Part 1
For additional coverage, read these articles in Tax Notes:
- Practitioner Slams Maryland’s New Digital Advertising Tax
- Maryland AG Argues for Dismissal of Verizon, Comcast Digital Ad Tax Suit
- Federal Judge Recuses Herself From Maryland Digital Ad Tax Case
- Maryland Digital Ad Tax Plaintiffs Won't Reveal Some Members
- TIA Not a Barrier to Maryland Digital Ad Tax Suit, Plaintiffs Argue
- Tax Law Professors Aid Maryland in Digital Ad Tax Suit
- Maryland Digital Ad Tax Suit Not Ripe, AG Argues
Follow us on Twitter:
- Lauren Loricchio: @LaurenLoricchio
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
In the first of a two-episode series, Professor Young Ran (Christine) Kim of the University of Utah College of Law discusses her views on the federal lawsuit challenging Maryland’s digital advertising tax.
Listen to our last episode on the digital advertising taxes: Digital Advertising Taxes and the States
For additional coverage, read these articles in Tax Notes:
- Practitioner Slams Maryland’s New Digital Advertising Tax
- Maryland AG Argues for Dismissal of Verizon, Comcast Digital Ad Tax Suit
- Federal Judge Recuses Herself From Maryland Digital Ad Tax Case
- Maryland Digital Ad Tax Plaintiffs Won't Reveal Some Members
- TIA Not a Barrier to Maryland Digital Ad Tax Suit, Plaintiffs Argue
- Tax Law Professors Aid Maryland in Digital Ad Tax Suit
- Maryland Digital Ad Tax Suit Not Ripe, AG Argues
Follow us on Twitter:
- Lauren Loricchio: @LaurenLoricchio
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Professor Goldburn P. Maynard Jr. of the Indiana University Kelley School of Business discusses the U.S. tax code’s effect on wealth inequality and how race has shaped the distribution of wealth.
Listen to more Tax Notes Talk episodes from our critical tax theory series:
- Feminism and the Tax Code
- Taxes and the LGBTQ Community
- Addressing Racial Inequity in State and Local Tax Policy
- The Tax Code and Economic Justice in America
- How Racial Diversity Shaped U.S. International Tax Policy
Follow us on Twitter:
- Joe Thorndike: @JThorndike
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
Sources mentioned in the intro:
- Institute for Policy Studies analysis
- Brookings data
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
National Taxpayer Advocate Erin Collins discusses the effect of the COVID-19 pandemic on taxpayers, recent IRS program changes, and what’s to come from the annual Taxpayer Advocate Service report to Congress.
In our “In the Pages” segment, David Hasen, a professor at the University of Florida Levin College of Law, chats about his recent Tax Notes piece, "Three Cheers for Proposed Changes to Partnership Debt Basis Allocation Rules."
For additional coverage, read these articles in Tax Notes:
- Private Tax Collection Shake-Up as One Contractor Replaces Two
- House Panel Approves IRS Budget Boost as Rettig Seeks More
- Millions Anxious for IRS Guidance on Unemployment, Advocate Says
- Wyden Bill ‘Imminent’ to End Private Garnishment of Stimulus Pay
- Caseload Fluctuations Concern National Taxpayer Advocate
- IRS Funding Tops Taxpayer Advocate’s Legislative Recommendations
Follow us on Twitter:
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.
We are excited to announce the new Tax Notes Transfer Pricing Center! For more information, visit taxnotes.com/transferpricing.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Professor Jacob Goldin of Stanford Law School discusses proposed changes to the advance child tax credit in draft legislation recently released by House Democrats.
Listen to our last episode on the advance child tax credit: The Advance Child Tax Credit: What Lies Ahead
For additional coverage, read these articles in Tax Notes:
- Child Tax Credit Targeted as Dems Clip Budget Bill
- Biden Would Consider Lower Child Credit Income Phaseout
- Expats Protest Exclusion From Expanded Child Tax Credit
- Olson: Getting Child Tax Credits to Families Must Be IRS Priority
- Colorado Governor Launches Campaign to Ease Access to Child Tax Credit
- Sen. Brown Pledges Permanent Child Credit Expansion
- All’s Fair in Getting Child Credits Paid, Advocate Argues
Follow us on Twitter:
- Marie Sapirie: @MarieSapirie
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.
We are excited to announce the new Tax Notes Transfer Pricing Center! For more information, visit taxnotes.com/transferpricing.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Tax Notes chief correspondent Stephanie Soong Johnston recaps the final agreement on the OECD’s two-pillar corporate tax reform plan approved in October by 136 countries of the inclusive framework.
Listen to more podcast episodes on the OECD's tax reform plan:
- The Beginning of the End? An Update on the OECD Tax Reform Plan
- New Year, New Tax Rules? An OECD Tax Reform Project Update
- Delays Ahead: An Update on the OECD’s Global Corporate Tax Reform
- A New Tax World Order: Coming Soon?
For additional coverage, read these articles in Tax Notes:
- G-20 Finance Chiefs Approve OECD Global Tax Reform Deal
- EU Should Consider Nondiscriminatory Implementation of Pillar 2
- Treasury Closing In on Digital Tax Repeal Deals With Countries
- EU Will Propose a Pillar 2 Directive by Year-End
- Hill Staffers Split on Pillar 1 Treaty Requirement
- Countries Finalize Sweeping OECD Global Tax Reform Agreement
- Argentina Says Global Tax Deal Is Bad for Developing Nations
Follow us on Twitter:
- Stephanie Soong Johnston: @SoongJohnston
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
In our “In the Pages” segment, Lucas de Lima Carvalho, an international tax law professor at the Brazilian Institute of Tax Law, chats about his recent Tax Notes piece, "The Andean Question: Two Pillars, Two Sides?"
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Tax Notes reporter Sarah Paez discusses the EU tax haven blacklist and the potential impact of the recently released Pandora Papers.
Read Sarah's article on the EU blacklist here: EU Tax Haven Blacklist Hamstrung by Politics, Critics Say
For additional coverage, read these articles in Tax Notes:
- MEPs Demand Action Against Tax Avoidance After Pandora Papers
- Pandora Papers Leak Details Widespread Use of Offshore Entities
- Turkey Evades EU Tax Haven Blacklist Once Again
- EU Code of Conduct Group Reviewing Scope of Blacklist Criteria
Follow us on Twitter:
- Sarah Paez: @PaezWrites
- David Stewart: @TaxStew
- Tax Notes: @TaxNotes
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
We are excited to announce the new Tax Notes Transfer Pricing Center! For more information, visit taxnotes.com/transferpricing.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Tax Notes Capitol Hill reporters Doug Sword and Frederic Lee return to discuss the latest tax developments with the record-breaking infrastructure and reconciliation legislation advancing in Congress.
Listen to the last Tax Notes Talk episode about Congress: Keeping Up With Congress: Fall 2021 Preview
For additional coverage, read these articles in Tax Notes:
- ‘We Need to Get a Number,’ Neal Says of Reconciliation Stalemate
- Neal Continues Push for Action on Retirement Issues
- Democrats Move Off $3.5 Trillion Figure, Infrastructure Link
- House Sets Up $3.5 Trillion Reconciliation Bill for Floor Vote
- Bank Reporting In, Stepped-Up Out of Tax Bill Options, Neal Says
- Congressional Democrats Shifting on Key Tax Items
- Wyden Looks to Tighten Rules Partnerships Use to Sidestep Taxes
In our “In the Pages” segment, Lynn Gandhi, a partner with Foley & Lardner LLP, chats about her recent Tax Notes cover piece, "Zelinsky — Round 2 of the Convenience of the Employer Test."
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Professors Bridget J. Crawford of the Pace University School of Law and Anthony C. Infanti of the University of Pittsburgh School of Law discuss viewing the U.S. tax code through a feminist lens.
Listen to more Tax Notes Talk episodes from our critical tax theory series:
- Taxes and the LGBTQ Community
- Addressing Racial Inequity in State and Local Tax Policy
- The Tax Code and Economic Justice in America
- How Racial Diversity Shaped U.S. International Tax Policy
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Jordan Bass of the firm Taxing Cryptocurrency discusses the proposed cryptocurrency tax changes that Congress is considering, and how they could affect taxpayers and the digital asset industry.
For additional coverage, read these articles in Tax Notes:
- House Democrats Propose Dramatic Changes to Wash Sale Rule
- Potential Breadth of Crypto Rules Worries Industry
- News Analysis: A Scorecard for Reconciliation, Round 2
- Ramp Up Crypto Reporting Now, Say Tax Pros
- Practitioner Suggests Another Look at Crypto-Specific Amnesty
- The Cryptocurrency Legislative Battle Is Far From Over
- News Analysis: DeFi-ing Crypto Financial Regulation
In our “In the Pages” segment, Rob Warren, assistant professor of accounting at the Radford University Davis College of Business and Economics, chats about his recent Tax Notes piece, "More Tax Cops Are Needed to Close the Tax Gap."
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Mark Strimber of RSM US LLP provides an overview of the global minimum tax rule featured in the OECD/G-20’s two-pillar project and discusses the effect it could have on various tax regimes.
Listen to the episode with Tax Notes chief correspondent Stephanie Soong Johnston here: The Beginning of the End? An Update on the OECD Tax Reform Plan
For additional coverage, read these articles in Tax Notes:
- U.S. Must Be Bold in Global Minimum Tax Effort, Treasury Says
- Yellen Touts OECD Tax Deal Amid U.S. Global TCJA Reform Push
- Togo Joins OECD Inclusive Framework and Global Tax Reform Deal
- OECD Tax Reform Plan Makes Sense for Ireland and EU, Macron Says
- German-Speaking Finance Ministers Commit to OECD Progress
- Hungary Does Not Believe in Global Minimum Tax Rate
- Barbados Joins OECD Corporate Tax Reform Plan
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Nikki Dobay, a partner with Eversheds Sutherland’s tax practice group, discusses the SALT cap workarounds for passthrough entities that many states have adopted, and possible coming developments for those policies.
For additional coverage, read these articles in Tax Notes:
- Illinois Governor Signs Passthrough SALT Cap Workaround
- Less Expensive SALT Cap Rollbacks Still Mostly Benefit Wealthy
- New York Issues Guidance on SALT Cap Workaround
- Surge of SALT Workarounds Could Pose Complications for Passthroughs
- California Democrats Join Call to Lift SALT Deduction Cap
In our “In the Pages” segment, Philip Wolf, associate at Belcher, Smolen & Van Loo LLP, chats about his new Tax Notes column, The Tax Scribe, and his first installment of the column, "Starting Strong in Tax Writing: The Opening Paragraph."
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by SafeSend. For more information, visit safesend.com.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Tax Notes Capitol Hill reporters Doug Sword and Frederic Lee examine the record-breaking budget and infrastructure legislation advancing on Capitol Hill and preview potential tax policy proposals coming this fall.
For additional coverage, read these articles in Tax Notes:
- Will Dems Pay Full Freight on $3.5 Trillion Reconciliation Bill?
- International Tax Draft Offers New Details, but Major Gaps Remain
- House Passes Budget Bill; Flurry of Markups to Follow
- Democrats Promise, GOP Fumes as $3.5 Trillion Package Advances
- Infrastructure Bill Heads to House for Potential Crypto Changes
- Ways and Means Dems Gaming Out How to Raise $3.5 Trillion
- California Democrats Join Call to Lift SALT Deduction Cap
- Members Hope SALT Caucus Is Short-Lived
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Tax Notes legal reporter Ryan Finley discusses the latest updates in recent transfer pricing cases, including Coca-Cola and Medtronic, and reviews the upcoming Amgen case.
The Coca-Cola episode can be listened to here: Coca-Cola Transfer Pricing Challenge Fizzles
For additional coverage, read these articles in Tax Notes:
- Amgen Disputes $3.6 Billion Deficiency in Transfer Pricing Case
- Medtronic Doubles Down on Its Use of CUT Method in New Trial
- Tax Court Sides With IRS in Coca-Cola Transfer Pricing Case
- Citing Comparability Questions, Eighth Circuit Vacates Medtronic
- Court Finds IRS Arbitrary and Capricious in Medtronic Transfer Pricing Case
In our “In the Pages” segment, Stephen Curtis, president of Cross Border Analytics Inc., chats about his Tax Notes piece, “Apple’s Cost-Sharing Arrangement: Frankenstein’s Monster.”
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
In the second of a two-episode series, Tax Notes contributing editor Marie Sapirie interviews Shuting Pomerleau, a climate policy analyst at the Niskanen Center, about her views on a carbon tax.
The first episode in the series can be listened to here: The Case Against a Carbon Tax
For additional coverage, read these articles in Tax Notes:
- Israel to Introduce Carbon Tax
- EU to Delay CBAM, ETS Own Resources Proposals
- G-20 Finance Ministers Call for More Carbon Pricing Coordination
- New U.S. Position on Climate Change Doesn't Portend Carbon Tax
- Can a Tax Save the Planet?
**
This episode is sponsored by the National Society of Accountants. For more information, visit nsacct.org.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
In the first of a two-episode series, Tax Notes contributing editor Marie Sapirie interviews David Kreutzer, an economist at the Institute for Energy Research, about his views on a carbon tax.
For additional coverage, read these articles in Tax Notes:
- Israel to Introduce Carbon Tax
- EU to Delay CBAM, ETS Own Resources Proposals
- G-20 Finance Ministers Call for More Carbon Pricing Coordination
- New U.S. Position on Climate Change Doesn't Portend Carbon Tax
- Can a Tax Save the Planet?
In our “In the Pages” segment, Walter Hellerstein, Distinguished Professor Emeritus at the University of Georgia Law School and chair of the Tax Notes State advisory board, chats about his Tax Notes piece, “Platforms: The Postscript.”
**
This episode is sponsored by the National Society of Accountants. For more information, visit nsacct.org.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Tax Notes reporters Amanda Athanasiou and Lauren Loricchio share what they learned reporting on their recent piece, “How the Pandemic Upended Life and Work for Women in Tax,” and their personal experiences.
For additional coverage, read Athanasiou's article in Tax Notes:
- Why Women Are Still Leaving Tax, and What to Do About It
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Tax Notes chief correspondent Stephanie Soong Johnston recaps the historic agreement reached by the majority of the OECD's inclusive framework countries on its two-pillar corporate tax reform proposal.
For additional coverage, read these articles in Tax Notes:
- OECD Tax Chief Outlines Next Steps for Global Tax Reform Deal
- Ireland to Start Consultation on Global Tax Reform Deal Soon
- EU Digital Levy Delay Is Welcome News, OECD Deputy Chief Says
- Amount A Plan Is a Formulary Approach Test, OECD Official Says
- Countries Advance Historic Global Tax Plan With New Details
- Pillar 1 of Global Tax Deal on a Slower U.S. Track, Yellen Says
- Brady Skeptical of Global Tax Deal Amid EU Digital Levy Push
In our “In the Pages” segment, Lewis Greenwald, managing director with Alvarez and Marsal Taxand, chats about his Tax Notes piece, “On the Exceptional Importance of Intercompany Agreements That Can Be Readily Produced.”
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Andrew Dana, a partner with Parker Poe Adams & Bernstein LLP, discusses the Supreme Court case NCAA v. Alston; name, image, and likeness rights; and how both could affect taxation of college athletes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Liz Armbruester, Avalara's senior vice president of global compliance, discusses the recent EU VAT e-commerce reforms and their impact on businesses and consumers worldwide.
For additional coverage, read these articles in Tax Notes:
- EU Assures No Further Postponement of VAT E-Commerce Rules
- European Commission Clarifies Scope of New VAT E-Commerce Rules
- European Commission Proposes Delaying E-Commerce VAT Rules
- EU Fleshes Out Anti-Fraud Measures for New VAT Regime
In our “In the Pages” segment, Margaret Ryznar, a professor at Indiana University McKinney School of Law , chats about her upcoming Tax Notes piece, “A Tax Credit for Wills.”
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Omeed Firouzi with Philadelphia Legal Assistance discusses the upcoming advance child tax credit payments and the related potential challenges for taxpayers and practitioners.
For additional coverage, read these news articles and analyses in Tax Notes:
- What to Know About the New and Upcoming Child Tax Credit Portals
- Advance Child Credit Payment Denials Must Be Reviewed, ABA Says
- IRS Planning Outreach Blitz for Nonfilers Eligible for Advance CTC
- Practitioners Cast Wary Eye on Periodic Advance Child Credit
- Advance Child Credit Guidance and Portal Coming, IRS Says
- The Expanding Child Tax Credit and What to Watch For
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Rajat Bansal, a departing member of the U.N. Committee on Experts on International Cooperation in Tax Matters, recaps the group’s milestones over the last four years and describes what challenges lie ahead.
For additional coverage, read these articles in Tax Notes:
- The Evolution of the U.N. Tax Model — Software Payments as Royalties
- U.N. Tax Committee Notes Support for Revising Royalty Definition
- U.N. Releases New Transfer Pricing Manual for Developing Countries
- U.N. Tax Committee Greenlights Carbon Taxation Handbook
- U.N. Committee Approves Digital Services Tax Treaty Article Text
- Proposed U.N. Model Treaty Article on DST on Track for 2021
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith
Showrunner: Paige Jones
Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Joseph Bishop-Henchman of the National Taxpayers Union Foundation discusses the litigation of a provision in the American Rescue Plan Act restricting states from using federal funds provided by the law to offset reductions in net tax revenue.
For additional coverage, read these articles in Tax Notes:
- Civil Liberties Group Sides With Ohio in Offset Provision Lawsuit
- Ohio Attorney General Seeks Permanent Injunction in Tax Restriction Suit
- Offset Provision Guidance Could Be Thorny for States Eyeing Tax Cuts
- Judge Denies Ohio's Request to Prevent Treasury From Enforcing Offset Provision
- Judge Dismisses Missouri's Suit Over Restriction on Federal Funding
- Federal Government Argues 13 States Lack Standing for Preliminary Relief
- Treasury Issues Much-Awaited Guidance on Tax Offset Provision
In our “In the Pages” segment, University of Virginia School of Law professor Ruth Mason chats about her recent Tax Notes piece, “State Aid Enforcement After Amazon.”
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith
Showrunner: Paige Jones
Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Professor Patricia A. Cain of the Santa Clara University School of Law discusses the unique tax challenges faced by members of the LGBTQ community in the past and today.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith
Showrunner: Paige Jones
Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Kevin Brown, an associate with Morrison & Foerster LLP, discusses his proposal for taxing moon-based activity.
Read Brown's piece in Tax Notes, "Tax the Moon That the Earth May Prosper: How to Tax Lunar Occupation."
In our “In the Pages” segment, Steven N.J. Wlodychak, the former indirect state and local tax policy leader for EY, discusses his recent Tax Notes piece, “Why Aren’t U.S. States Subject to International Tax Treaties?”
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Janelle Julien
Showrunner: Paige Jones
Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Tax Notes legal reporter Jennifer McLoughlin and contributing editor Kristen Parillo discuss two important tax cases heard by the Supreme Court: Americans for Prosperity Foundation and CIC Services.
For additional coverage, read these articles in Tax Notes:
- Limitations of CIC Services Opinion Are Unclear
- Lawsuit on Access to Appeals Barred Under CIC Services, DOJ Says
- Supreme Court’s CIC Services Opinion Clarifies Scope of AIA
- Professor Highlights Potential Reach of California Donor Disclosure Case
- California Donor Disclosure Law Is Chilling, Attorney Tells SCOTUS
- U.S. Lawmakers Seek Justice Barrett’s Recusal in Donor Disclosure Case
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producer: Jasper B. Smith
Showrunner: Paige Jones
Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Tax Notes legal reporters Ryan Finley and Kiarra M. Strocko discuss the EU General Court’s judgments in Amazon and Engie and their effect on state aid rules.
For additional coverage, read these articles in Tax Notes:
- Amazon May Force the EU Commission to Change Its Approach
- Amazon and Engie Cast Doubt on State Aid Enforcement Approach
- Engie Loses €120 Million Tax Fight Against European Commission
- Luxembourg Gets Resounding Win in Amazon State Aid Decision
- Amazon Must Repay €250 Million in Unpaid Taxes to Luxembourg, European Commission Says
In our “In the Pages” segment, Alan D. Viard, a resident scholar at the American Enterprise Institute, discusses his upcoming Tax Notes piece, “Notches in the Tax System: the Good, the Bad, and the Ugly.”
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producer: Jasper B. Smith
Showrunner: Paige Jones
Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Tax Notes contributing editor Robert Goulder discusses the Biden administration’s approach to the OECD’s two-pillar solution to taxing the digital economy and the potential for global consensus.
For additional coverage, read Goulder's piece in Tax Notes:
- Treasury’s Pillar 1 Reset: In Praise of Comprehensive Scoping
- All Roads Lead to Ireland: Pillar 2 and the Path of Least Resistance
- The BEPS Gambit: Will the OECD Know When to Resign?
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Janelle Julien
Showrunner: Paige Jones
Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Jonathan Curry of Tax Notes recaps the tax provisions of President Biden’s American Families Plan and discusses with Dean Zerbe of Alliantgroup the finer details and its likelihood of passing Congress.
For additional coverage, read these articles in Tax Notes:
- Yellen Leaves Door Open to Deficit-Financing Biden’s Big Plans
- Biden’s NII Tax Fix Destined to Be the Bane of Practitioners
- Republicans Denounce Biden’s Tax Hike Proposals
- Like-Kind Exchange Proposal Is a Job Killer, Say Pros
- Democrats See Room for Improvement in Some Biden Tax Proposals
- Biden’s Next Plan Targets Like-Kind Exchanges, Stepped-Up Basis
- Biden Tax Gap Plans Prompt Business, Taxpayer Rights Concerns
- Biden Sets Date to Unveil Tax Proposals Aimed at the Rich
Charlotte Tolman of Stibbe discusses her new Tax Notes column, “In Step With Stibbe.”
Check out our episode on the first package of President's Biden Build Back Better plan, "The Biden and Wyden Tax Plans."
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Janelle Julien
Showrunner: Paige Jones
Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Enrolled agents Eva Rosenberg and Jeffrey Schneider share their experiences on communicating with the IRS during the coronavirus pandemic and how the agency can improve.
For additional coverage, read these articles in Tax Notes:
- IRS Remote Employees Mull Telework Despite Processing Backlogs
- IRS Backlogs to Last at Least Until Summer, Taxpayer Advocate Says
- Found Money and Powerlessness: Tax Pros Share 2021 Ups and Downs
- Return Filing Extension Receives Widespread Approval
- IRS Data Analytics Pros Still See Need for Human Touch
- IRS Exec Pushes for Agency ‘Digitalization’ Funding
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Janelle Julien
Showrunner: Paige Jones
Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
David Thompson of the National Council of Nonprofits talks about how tax policy affects tax-exempt organizations and tax issues on the nonprofit industry’s radar today.
For additional coverage, read these articles in Tax Notes:
- IRS Official Outlines Status of EO Examinations
- IRS Clarifies Reporting of Emergency Grants to College Students
- Lawmakers Reintroduce Legislation to Expand Charitable Deduction
- IRS Tackling Coronavirus Guidance for EOs
- Nonprofits Seek Enhanced Giving Deduction for Non-Itemizers
Brian Hamer of the Multistate Tax Commission discusses his recent Tax Notes piece “An Insider’s View of the MTC’s P.L. 86-272 Project.”
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Janelle Julien
Showrunner: Paige Jones
Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Tax Notes reporters examine President Biden’s Made in America Tax Plan and the international tax framework by Senate Finance Committee Chair Ron Wyden, D-Ore., and their international impact.
For additional coverage, read these articles in Tax Notes:
- Wyden Cheers New Treasury Pitch in OECD Global Tax Reform Talks
- Brady Lambastes Potential Tax Hikes as Invitation for Inversions
- Treasury Ties Corporate Reforms to Improved U.S. Competitiveness
- Biden Administration’s ‘SHIELD’ Proposal Would Replace BEAT
- Senate Dems Pitch International Tax Changes With No Set Rates
- Yellen Stresses Global Cooperation on Minimum Corporate Taxation
- Tax Code Plays Big Role in Biden’s Infrastructure Plans
- Biden Proposes Eliminating FDII, Changing Earnings-Stripping Law
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Janelle Julien
Showrunner: Paige Jones
Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Abdul Muheet Chowdhary of South Centre, an intergovernmental organization of developing countries, talks about how the U.N. Committee on Experts on International Cooperation in Tax Matters could be more transparent and effective for developing countries.
Read his piece in Tax Notes, "Making the U.N. Tax Committee More Effective for Developing Countries."
Thomas S. Neubig of the of the Council on Economic Policies talks about his recent Tax Notes piece, “Disparate Racial Impact: Tax Expenditure Reform Needed.”
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Janelle Julien
Showrunner: Paige Jones
Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Joel Slemrod and Michael Keen, authors of Rebellion, Rascals, and Revenue: Tax Follies and Wisdom Through the Ages, share interesting tax facts and lessons learned from history.
Check out our related episode "From Henry VIII to James Bond: Weird Tax Facts Throughout History."
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Janelle Julien
Showrunner: Paige Jones
Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Benjamin Angel, director of direct taxation at the European Commission’s Directorate-General for Taxation and Customs Union, discusses the EU’s biggest tax challenges and what lies ahead.
For additional coverage, read these articles in Tax Notes:
- EU Digital Levy Won't Be Discriminatory, Vestager Says
- Economist Says Electricity Tax Cuts Will Help Countries Go Green
- OECD Agreement Vital to Achieving Tax Fairness, EU Lawmakers Say
Nicholas Kuria of Conyers Dill & Pearman talks about his recent Tax Notes piece, “Tax and the British Virgin Islands: Separating Myth From Reality.”
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Janelle Julien
Showrunner: Paige Jones
Audio Engineers: Jordan Parrish, Aeris Stewart
Guest Relations: Christa Goad
Martin A. Sullivan of Tax Notes and Tynisa Gaines, an enrolled agent, discuss the tax provisions of the new coronavirus relief package and its impact on the economy and the tax community.
For additional coverage, read these articles in Tax Notes:
- Return Filing Extension Receives Widespread Approval
- House Approves Two-Month PPP Extension
- Preparers Eager for Guidance on Unemployment Exclusion, Credits
- Biden Signs $1.9 Trillion COVID-19 Relief Bill Into Law
- House Sends Massive COVID-19 Relief Bill to Biden
- Money on the Way as IRS Gears Up for Stimulus Round 3
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
This episode is sponsored by Graduate Tax Program at LMU Loyola Law School. For more information, visit lls.edu/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Janelle Julien
Showrunner: Paige Jones
Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Yvette Lind, an assistant professor of tax law at the Copenhagen Business School, talks about how the coronavirus pandemic hurt gender equality and offers possible tax solutions.
For additional coverage, read Lind's special report in Tax Notes: "Gender Equality, Taxation, and the COVID-19 Recovery: A Study of Sweden and Denmark."
Alexandre Marcellesi of Gibson, Dunn & Crutcher discusses his upcoming article in Tax Notes on creditor continuity of interest. **
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Janelle Julien
Showrunner: Paige Jones
Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Paul Tang, a Dutch member of the European Parliament, discusses the challenges facing the international tax community and his goals as chair of the subcommittee on tax.
For additional coverage, read these articles in Tax Notes:
- EU Must Consider Removing VAT Exemption for Financial Services
- Paul Tang Discusses The Future of EU Tax
- EU Parliament Tax Subcommittee to Focus on New Revenue Sources
- European Parliament Names Members of Permanent Tax Subcommittee
- European Parliament Tax Subcommittee to Formalize Leadership
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Janelle Julien
Showrunner: Paige Jones
Audio Engineer: Jordan Parrish
Guest Relations: Christa Goad
Rebecca Thompson of Prosperity Now, a nonprofit based in Washington, D.C., discusses how the COVID-19 pandemic has affected low-income communities and families of color in the United States, and what tax policy tools could help them.
For additional coverage, read these articles in Tax Notes:
- IRS Plan for Monthly Child Credit Distribution Lacks Details
- IRS Has No Plans to Extend 2021 Filing Season Nationwide
- Calls Grow for Tax Return Filing Deadline Extension
- House Democrats to Fight Injustices With Incentives
University of Virginia professor Andrew Kahrl talks about his recent Tax Notes piece, “More for Less: How Property Taxes Fuel Racial Inequality."
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Janelle Julien
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole Wilder
Josh Goodman of the Pew Charitable Trusts talks about the organization’s recent report on how states can direct economic development to people and places in need.
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Janelle Julien
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole Wilder
Phyllis Jo Kubey, a solo practitioner based in New York City, and Ryan L. Losi, executive vice president at PIASCIK, discuss the 2021 tax season and the unique challenges posed by the COVID-19 pandemic.
For additional coverage, read these articles in Tax Notes:
- Late Start to Filing Season Has More Preparers Wanting Extra Time
- Tax Pros Debate Later Filing Season Opening — And Closing
- 2020 Tax Woes Likely to Haunt Practitioners Into Next Year
- CPAs Tackle COVID Tax Impact on Athletes
- COVID-19 Shaped Tax Pros’ Business Through Filing Season
- Preparers Scramble in Pandemic Adapt-to-Survive Moment
- Business of Tax: The Strangest Filing Season in Memory
International tax attorney Paul J. Crispino talks about his upcoming Tax Notes piece, “Veering Off Course: Targeted Advertising and Market Taxation.”
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Janelle Julien
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole Wilder
Morgan Scarboro of MultiState discusses the tax topics state legislatures are likely to tackle this year.
For additional coverage, read these articles in Tax Notes:
- Experts, Activists Weigh In on Proposed Washington State Wealth Tax
- Connecticut Bill Looks to Prevent Double Taxation of Remote Workers
- Maryland Bill Would Disallow Retroactive Tax Breaks in CARES Act
- Kansas House Panel Proposes Marketplace Facilitator Bill
- Connecticut Rep Proposes Digital Ad Tax on Social Media Companies
- Local Officials Press Congress for Aid
- Missouri Governor Calls on Lawmakers to Address Wayfair
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole Wilder
Tax Notes reporters Jad Chamseddine and Alexis Gravely speculate on upcoming tax changes and developments on Capitol Hill this year.
Jeffrey A. Friedman of Eversheds Sutherland (US) LLP talks about his recent Tax Notes piece, “The Complexities of State Taxation of Digital Advertising.”
For additional coverage, read these articles in Tax Notes:
- Wyden Eyes Corporate Tax, Capital Gains Reform as Finance Chair
- Tax Staffers Highlight Focus on Bipartisanship for 117th Congress
- Ways and Means Set to Welcome Three New GOP Members
- Date Scheduled to Determine Fate of Trump’s Tax Returns
- Senate Confirms Yellen as Treasury Secretary
- Immediate Tax Increases Unlikely, Treasury Official Says
- Retirement and Health Benefits Seen as Likely Revenue Offsets
**
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole Wilder
Tax Notes reporters Stephanie Soong Johnston and Ryan Finley recap the OECD’s latest public consultation on its two-pillar approach to taxing the digital economy.
For additional coverage, read the article in Tax Notes:
- Stakeholders Push for ‘Angel List’ in OECD Minimum Tax Plan
- U.S. Must Rethink Stance on Global Tax Reform Deal, Harter Says
- Delivering on Tax Certainty Is Critical to Pillar 1’s Success
- OECD Navigates Calls for Simplifying Global Tax Reform Plan
- OECD Opens Global Tax Meeting to Public for the First Time
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole Wilder
Retired IRS economist Kim Bloomquist discusses his findings of geographic – and perhaps race and class – bias in the tax agency’s selection of audits.
For additional coverage, read these articles in Tax Notes:
- IRS Exams Focus on EITC Claims, Not Poor, Inspector General Says
- Audit Patterns Not Racially Biased, IRS Chief Tells House Panel
- Rettig to Tax Pros: Get Clients in the Compliance ‘Zone’
Scott St. Amand of Fisher, Tousey, Leas & Ball talks about his upcoming Tax Notes piece, “Prior Supervisory Approval: The Tax Penalty Poison Pill.”
**
This episode is sponsored by the Tax Attorney Recruiting Event (TARE). For more information, visit the-tare.com.
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole Wilder
Martin Hearson of the International Centre for Tax and Development and Emmanuel Eze of the Nigerian Federal Inland Revenue Service discuss the role and influence of developing countries in the OECD’s inclusive framework.
For additional coverage, read these articles in Tax Notes:
- Study Sheds Light on Inclusivity of OECD Global Tax Negotiations
- Lower-Income Countries Must Collaborate for Tax Policy Sway
- A Look Ahead: Hurry Up and Wait for a Global Tax Reform Deal
- OECD Nails Down Date for Public Meeting on Tax Reform Blueprints
- G-20 Leaders Reaffirm Commitment to Progress on Global Tax Deal
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by the Tax Attorney Recruiting Event (TARE). For more information, visit the-tare.com.
This episode is sponsored by the D.C. Bar. For more information, visit dcbar.org.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole Wilder
Tax Analysts Chief Content Officer Jeremy Scott reviews U.S. tax legislation passed in 2020 and speculates about what lies ahead in 2021.
For additional coverage, read the article in Tax Notes:
- A Look Ahead: COVID-19 Relief Likely to Be Yellen’s Legislative Focus
- Trump Signals He May Not Sign COVID-19 Relief Bill
- A Look Ahead: Biden Expected to Mend Fences at WTO
- Congress Passes Year-End Bill With Full PPP Deductibility
- Progressive Tax Aspirations Thwarted by Split Congress
In the segment “In the Pages,” Tax Notes International Editor in Chief Cathleen Phillips talks about how (and why) to write for Tax Notes.**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by the D.C. Bar. For more information, visit dcbar.org.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole Wilder
Tax Notes reporters recap some of the quirkiest tax stories they encountered in2020, from two brothers’ legal and tax troubles to Mexico’s acceptance of art created by artificial intelligence to pay taxes.
For additional coverage, read the article in Tax Notes:
- Pandemic Spooks Salem's Tourism Tax Revenue This Halloween
- Ping Pong Tops Colorado’s First Month of Sports Betting
- Door Swings Both Ways Denying Equitable Remedies to Tax Schemers
- Nominee Tax Dodging Scheme Backfired
- Mexico Accepts Artificial Intelligence Images to Pay Taxes
In the segment “In the Pages,” Tax Notes State Editor in Chief Jéanne Rauch-Zender talks about how (and why) to write for Tax Notes.**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
This episode is sponsored by the D.C. Bar. For more information, visit dcbar.org.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole Wilder
Miller & Chevalier member Loren Ponds shares her journey from Georgetown University Law Center to the OECD to Capitol Hill, where she worked on the 2017 tax law, and what she learned along the way.
For additional coverage, read the article in Tax Notes "Walking a Unique Path: A Conversation With Miller & Chevalier’s Loren Ponds."
This interview published on the Miller & Chevalier podcast tax break.
In the segment In the Pages, Tax Notes Federal Editor in Chief Ariel Greenblum talks about how (and why) to write for Tax Notes.**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
This episode is sponsored by the D.C. Bar. For more information, visit dcbar.org.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole Wilder
U.S. Tax Court Chief Judge Maurice B. Foley discusses his path to the bench, the court’s new case management system, and pivoting to virtual during the coronavirus pandemic.
For additional coverage, read these articles in Tax Notes:
- Tax Court Hopes More Practitioners Will Use Remote Trials
- Learning Curves, Adaptation Predicted for Remote Tax Court Trial
- Coronavirus Measures Will Leave Tax Court More Accessible
- Tax Court Institutes Remote Hearings, E-Access to Court Docs
- Tax Court Proposes Formal Reference to Limited Appearances
- No Easy Solutions for Electronic Access to Tax Court Documents
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole Wilder
Tax Notes legal reporter Ryan Finley discusses the IRS’s major victory in the Coca-Cola case and its future implications for transfer pricing cases.
For additional coverage, read these articles in Tax Notes:
- U.S. Tax Court’s Coca-Cola Ruling: Early Sign of a New Approach?
- Tax Court Sides With IRS in Coca-Cola Transfer Pricing Case
- IRS, Coca-Cola Continue Fight Over Transfer Pricing Analysis
- Coca-Cola's Tax Court Petition Disputes the IRS's Transfer Pricing Adjustments
Economist Andrew Hughes talks about his upcoming series in Tax Notes on transfer pricing benchmarks.
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
The Tax Foundation’s Ulrik Boesen discusses the excise taxes imposed on longtime vices like alcohol and cigarettes as well as more recently developed habits.
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
This episode is sponsored by the Graduate Tax Program at Loyola Law School. For more information, visit lls.edu/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Tax Notes senior legal reporter Andrew Velarde and contributing editor Robert Goulder discuss the influence of the 2020 U.S. elections on the international tax world.
For additional coverage, read these articles in Tax Notes:
- Biden’s International Tax Proposals Missing Many Pieces
- EU Hopes to Repair Bilateral Relationship With U.S.
- Biden Win Brings Hope for Progress in Global Tax Talks
TaxOps SALT expert Tram Le talks about her recently published piece, “Simplification Initiatives to Reduce Burdens for Remote Sellers.”
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Tax Notes reporters Alexis Gravely and Jonathan Curry discuss U.S. tax policy following the 2020 presidential election, and Tax Notes senior reporter Paul Jones talks about the results of state tax ballot measures.
For additional coverage, read these articles in Tax Notes:
- Retroactive Tax Hikes Seen as Unlikely Under Biden Administration
- Elections Viewed as Opportunity for O-Zone Reset
- Smaller COVID Relief More Likely as Dems Underperform in Election
- California, Alaska, and Illinois Voters Reject Tax Increases
- Governors Hold Seats, Montana Elects First Republican in 16 Years
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
On Tax Analysts’ 50th anniversary, CEO and President Cara Griffith reflects on the organization’s history as a longtime transparency advocate and how she plans to expand its legacy.
Kim Clausing, incoming professor at the University of California, Los Angeles Law School, talks about her upcoming Tax Notes piece, “Five Lessons on Profit Shifting From the US Country by Country Data.”
For additional coverage, read these articles in Tax Notes:
- Reflections on Thomas F. Field: Speaking on the Public Interest
- Tax History: Talking Tax: How We Stumbled Into Podcasting
- Journalists and Lawyers Report the News: A Little Help From My Friends
- SCOTUS Success: Tax Analysts’ 1989 Transparency Triumph
**
This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Five years ago, the OECD released its final report on the base erosion and profit-shifting project.
Tax Notes Talk host David D. Stewart chats with Deloitte’s Bob Stack, who represented the U.S. government at the OECD’s BEPS talks, about his thoughts on the project’s outcome and its effect on the OECD’s current work to overhaul the global tax system for the digital age.
For additional coverage, read these articles in Tax Notes:
- BEPS 5 Years Later: Action 1 and the Quest to Tax Digital Activity
- BEPS 5 Years Later: Tax Transparency as the Global Norm
- BEPS 5 Years Later: Practitioners Give MLI’s Effectiveness Mixed Reviews
- BEPS 5 Years Later: Still No Convergence on Transfer Pricing
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Tax Notes State Editor in Chief Jeanne Rauch-Zender talks with Amy Vetter, a keynote speaker and presenter, on how to survive – and thrive – personally and professionally despite the unique challenges presented by the coronavirus pandemic.
In the segment In the Pages, Tax Notes Executive Editor for Commentary Jasper B. Smith chats with reference attorney Linda Friedman about the new Document Comparison tool available to Tax Notes readers.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Tax Notes Talk host David D. Stewart chats with Tax Notes chief correspondent Stephanie Soong Johnston and Tax Notes contributing editor Nana Ama Sarfo about recent developments on the OECD’s work to rebuild the international corporate tax system for the digital age.
For additional coverage, read these articles in Tax Notes:
- G-20 Ministers Greenlight New Deadline for OECD Global Tax Accord
- OECD Now Aiming for Global Corporate Tax Reform Deal by Mid-2021
- EU Will Respect New OECD Deadline for Reaching Global Tax Deal
- OECD Chief to Push G-20 Ministers to Step Up on Global Tax Deal
- Countries Push U.S. to Curb BEAT in OECD Minimum Tax Proposal
- BEPS 5 Years Later: Action 1 and the Quest to Tax Digital Activity
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Tax Notes contributing editor Marie Sapirie talks with American University tax professor Caroline Bruckner about the lack of consideration by Congress on how the U.S. tax code affects women-owned businesses and what can be done.
For additional coverage, read Marie Sapirie's analysis in Tax Notes:
- A Seat at the Tax Hearing Table for Women-Owned Businesses
In the segment In the Pages, Tax Notes Executive Editor for Commentary Jasper Smith chats with the 2020 winner of the Christopher E. Bergin Award of Excellence in Writing, Alex Zhang of Yale Law School, about his winning paper, “The State and Local Tax Deduction and Fiscal Federalism.”
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Tax Notes contributing editor Joseph J. Thorndike and University of Iowa law professor Andy Grewal take a closer look at the The New York Times reporting on President Trump’s tax returns.
For additional coverage, read these articles in Tax Notes:
- Trump Disputes Reports, Claims He's Paid ‘Millions’ in Income Taxes
- Trump Tax Revelations Spur Fresh Calls for IRS, Tax Reforms
- Trump's Seven Springs Property Could Be Subject to SALT Cap
- Trump Tax Returns Call Consulting Fees Into Question
- Trump Tax Reveal Puts Spotlight on Organization's Business Practices
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Tax Notes reporter Nathan J. Richman talks with outgoing IRS Criminal Investigations division Chief Don Fort about his decades-long career with the tax agency, his plans for retirement, and the future of the division.
For additional coverage, read these articles in Tax Notes:
- Incoming CI Chief Plans New Law Enforcement Network
- Another Longtime CI Veteran Will Be Next Division Chief
- Practitioners Say Fort Is Leaving CI Better Than He Found It
- CI Chief Fort Retiring at End of September
- Criminal Tax Investigators Learning to Cope With Coronavirus
In the segment In the Pages, Tax Notes State Editor in Chief Jéanne Rauch-Zender chats with Lynn A. Gandhi, a partner and business lawyer with Foley & Lardner LLP, about her recent piece, “The Broad Reach of Michigan’s Industrial Processing Exemption.”
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Tax Notes contributing editor Roxanne Bland chats with Donnie Charleston, the public policy and advocacy director of the nonprofit E Pluribus Unum, about how state and local tax policies can exacerbate racial inequity and what some communities are doing to address it.
For more about the intersection of U.S. tax policy and racial wealth inequality, check out our podcast episode, "The Tax Code and Economic Justice in America."
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Allison Christians, the H. Heward Stikeman Chair in Tax Law at McGill University, tells Tax Notes Executive Editor for Commentary Jasper Smith about her principles for writing good papers in law school and beyond.
For additional coverage, read Christians's paper, "Really Basic Rules for Writing Good Papers in Law School."
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Tax Notes Today International Editor in Chief David D. Stewart talks with Tax Notes reporters Jonathan Curry and Alexis Gravely about the tax policies proposed by President Trump and Democratic presidential candidate Joe Biden.
For additional coverage, read these articles in Tax Notes:
- GOP Takes Subdued Victory Lap on TCJA at Republican Convention
- Payroll Tax Deferral for Federal Employees Prompts Criticism
- Biden Tax Agenda Gets Brief Nods at Democratic Convention
- Trump on the Hunt for Solutions to Payroll Tax Memo Problems
- Biden Would Fund Caregiving Plan by Cutting Like-Kind Exchanges
- Biden Wants to ‘Build Back Better’ With Business Tax Changes
In the segment In the Pages, Tax Notes Federal Editor in Chief Ariel Greenblum chats with Tax Notes contributing editor Benjamin M. Willis about the piece he coauthored, “Biden-Harris’s High Hopes for Mitigating Tax Rate Disparities.”
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Francine J. Lipman, a law professor at the University of Nevada, Las Vegas, talks with Darrick Hamilton, a stratification economist and the New School’s incoming Henry Cohen Professor of Economics and Urban Policy, about the intersection of U.S. tax policy and racial wealth inequality.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Tax Notes senior reporter Paul Jones talks with Richard C. Auxier, senior policy associate at the Urban-Brookings Tax Policy Center, about tax issues raised by the gig economy and how policymakers are working to address them.
Note: This episode was recorded prior to a California court decision mandating Uber and Lyft to reclassify drivers in the state as employees.
For additional coverage, read these articles in Tax Notes:
- California Chamber Backs Labor, Payroll Tax Exemption for App-Based Companies
- Labor, Payroll Tax Law Exemption for App-Based Companies on California Ballot
- Businesses, Lawmakers Urge Suspension of Pending Tax Policies
- Ride-Sharing Companies Fight California Labor Law on 2 Fronts
- Tax Pros Seek Clarity on California Insurance Mandate, Employment Law
- California FTB Mulls Gig Economy Tax Challenges
- California Governor Signs Employment Reclassification Law
In the segment “In the Pages,” Tax Notes Executive Editor for Commentary Jasper B. Smith interviews Tax Notes contributing editor Nana Ama Sarfo about her recent piece, “Rwanda Leading African Sustainable Investment Drive.”
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Tax Notes legal reporter Nathan J. Richman talks with IRS Chief Counsel Michael J. Desmond about pivoting to virtual settlement days amid the coronavirus pandemic.
For additional coverage, read these articles in Tax Notes:
- Lessons From Virtual Settlement Days Could Help Future Events
- Work-From-Home Technology Comes With New Privilege Concerns
- Virtual Settlement Days Will Continue, IRS Says
- IRS Collection Officials Seeing Settlement Day Benefits
- IRS Considering Long-Term Benefits of Settlement Conference Days
- IRS Settlement Conference Day Guide Implies Timing Flexibility
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Tax Notes chief correspondent Stephanie Soong Johnston and legal reporter Ryan Finley discuss Ireland and Apple Inc.’s state aid win with law professors Ruth Mason of the University of Virginia and Stephen Daly of King’s College London.
For additional coverage, read these articles in Tax Notes:
- Ireland’s Reputation Harmed by Apple State Aid Investigation
- Will the EU Commission Cut Its Losses After the Apple Decision?
- Crunch Time: What the Apple Decision Means for Global Tax Reform
- EU Court Rules Against Commission in Apple State Aid Case
- Neither Apple nor Ireland on Hook for Any Escrow Fund Losses
In the segment "In the Pages Sneak Peek," Tax Notes Federal Editor in Chief Ariel Greenblum chats with Alan I. Appel, director of the international tax program at New York Law School, about his recent piece, "The Hidden Marriage Penalty Inside the TCJA."
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Tax Notes reporter Alexis Gravely talks with Edward Karl, vice president of taxation at the American Institute of CPAs, about tax changes made and considered by Congress in the wake of the COVID-19 pandemic.
For additional coverage, read these articles in Tax Notes:
- Don’t Count Out PPP Deductibility, Senate Republicans Say
- Senate Coronavirus Relief Package Faces Uphill Battle
- Senate Relief Package Expands PPP, Extends Tax Credits
- AICPA Calls for PPP Clarity in Next Round of Virus Relief
- Small Businesses Need a ‘Future-Proof’ Tax System, AICPA Says
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Tax Notes contributing editor Robert Goulder talks with Steven A. Dean, faculty director of New York University School of Law’s graduate tax program, about the intersection of racial diversity and U.S. international tax policy.
For additional coverage, read Dean's piece in Tax Notes:
- FATCA, the U.S. Congressional Black Caucus, and the OECD Blacklist
In the segment "In the Pages Sneak Peek," Tax Notes Executive Editor for Commentary Jasper B. Smith chats with Lucas de Lima Carvalho, an international tax law professor at the Brazilian Institute for Tax Law, about his recent piece, "The Trouble With 'Pillars' in International Tax Policy."
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Tax Notes reporter Carolina Vargas interviews Tax Notes State contributing editor Roxanne Bland about the emerging trend among some states to tax digital advertising.
For additional coverage, read these articles in Tax Notes:
- D.C. Council Passes Digital Ad Tax in First Budget Vote
- Digital Advertising Taxes Trigger Foreign Commerce Clause Concerns
- Maryland Governor Vetoes Digital Ad Tax Bill
- Another New York Lawmaker Pushes for Digital Ad Tax
- Digital Advertising Tax Proposals: Revenue Booster or Unconstitutional?
- New York Lawmaker Proposes Digital Advertising Tax
- Nebraska Lawmaker Pushes for Digital Ad Tax
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Kelly Phillips Erb, the managing shareholder of Erb Law Firm PC, known as @taxgirl on Twitter, talks to Tax Notes reporter Jonathan Curry about the abnormal 2020 tax season.
For additional coverage, read these articles in Tax Notes:
- COVID-19 Shaped Tax Pros’ Business Through Filing Season
- No Extension of July 15 Filing Deadline, IRS Announces
- Work-From-Home Technology Comes With New Privilege Concerns
- Some Tax Pros Wary of Another Return Filing Extension
- Preparers Scramble in Pandemic Adapt-to-Survive Moment
- Business of Tax: All COVID-19, All the Time for Tax Wonks
In the segment “In the Pages Sneak Peek,” Tax Notes State Editor in Chief Jéanne Rauch-Zender talks with Robert Plattner about his recent piece, "Part 2: The Commerce Clause Strikes Back."
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Tax Notes International contributing editor Nana Ama Sarfo talks with Virginia La Torre Jeker, a U.S. tax attorney based in Dubai, about establishing her tax practice abroad, the challenge of balancing family life with career, and recent international tax issues.
For additional coverage, read these articles in Tax Notes:
- Conquering Hong Kong and Dubai: A Conversation With Virginia La Torre Jeker
- When Sharia and U.S. Tax Law Collide
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Lawrence A. Zelenak, the Pamela B. Gann Professor of Law at Duke University School of Law, shares his findings from watching dozens of hours of tax-related sitcom episodes.
For additional coverage, read these articles in Tax Notes:
- Seven-Plus Decades of the Federal Income Tax in Sitcoms: An Update
- Six Decades of the Federal Income Tax in Sitcoms
In the segment, “In the Pages Sneak Peek,” Tax Notes Federal Editor in Chief Ariel Greenblum talks with Philip Wolf about his new column, A Young Practitioner's Journey.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Tax Notes legal reporter Jennifer McLoughlin interviews Richard Cram, director of the Multistate Tax Commission’s National Nexus Program, on the state of the sales tax landscape two years after the Supreme Court ruling in South Dakota v. Wayfair Inc.
McLoughlin moderates a discussion between Bradley Scott, finance director of the jewelry component wholesaler Halstead Bead Inc., and Scott Peterson, vice president of U.S. tax policy and government relations at Avalara Inc.
For additional coverage, read these articles in Tax Notes:
- Smaller Sellers Searching for Relief in Post-Wayfair World
- Smaller Businesses Struggle Most With Post-Wayfair Compliance
- States Could Lower Nexus Thresholds to Address Revenue Shortfalls
- States Extend Sales Tax Deadlines, May Pass More Marketplace Bills
- Small Businesses Ask Congress to Act on Remote Seller Laws
- MTC Finalizes 2019 White Paper on Wayfair Implementation Issues
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
In the second part of a two-episode series, Tax Notes legal reporter Kristen Parillo interviews Steve Small, one of the authors of the federal income tax regulations on conservation easements who is now in private practice, about the controversy surrounding the tax treatment of conservation easements.
Read Steve Small's piece in Tax Notes:
- Some Dirty Realities About Syndicated Conservation Easements
For additional coverage, read these articles in Tax Notes:
- Partnership Asks for Do-Over in Easement Appeal
- IRS Win in Golf Course Easement Case Overturned
- Syndicated Easement Sponsor Warns Investors of IRS Audits
- Conservation Easement Safe Harbor May Allow Compromise
- DOJ Seeks to Leverage Conservation Easement Victory
- ‘Tide Has Turned’ on Easement Abuse, Says Desmond
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
In the first part of a two-episode series, Tax Notes legal reporter Kristen Parillo interviews Robert Ramsay, executive director of the Partnership for Conservation, about controversy surrounding conservation easements.
Read Robert Ramsay's piece in Tax Notes:
- A Dirty Dozen Myths About Conservation Easements and One Sad Truth
For additional coverage, read these articles in Tax Notes:
- Partnership Asks for Do-Over in Easement Appeal
- IRS Win in Golf Course Easement Case Overturned
- Syndicated Easement Sponsor Warns Investors of IRS Audits
- Conservation Easement Safe Harbor May Allow Compromise
- DOJ Seeks to Leverage Conservation Easement Victory
- ‘Tide Has Turned’ on Easement Abuse, Says Desmond
In our segment, “In the Pages Sneak Peek,” Tax Notes Executive Editor for Commentary Jasper Smith talks with Fenwick & West LLP’s Larissa Neumann about the recent piece she coauthored with James P. Fuller, "U.S. Tax Review."
This episode is sponsored by the Graduate Tax Program at LMU Loyola Law School in Los Angeles. For more information, visit www.lls.edu/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Joseph J. Thorndike, Tax Notes Federal contributing editor and tax historian, discusses the Supreme Court’s recent oral arguments on the legal cases involving President Trump’s tax returns and financial records.
For additional coverage, read these articles in Tax Notes:
- Supreme Court Weighs Limits, Burdens in Trump Tax Return Cases
- Judge Suggests Dismissing Trump Tax Returns Subpoena
- Judge Rejects Democrats’ Delay Request in Trump Tax Return Case
- Supreme Court Sets Hearing Date in Trump Tax Return Lawsuits
- Trump Again Asks Supreme Court to Block Financial Records Release
- Dems Urge Court Not to Give Trump Notice in NY Tax Return Quest
This episode is sponsored by the Graduate Tax Program at LMU Loyola Law School in Los Angeles. For more information, visit www.lls.edu/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Tax Notes colleagues David D. Stewart and Stephanie Soong Johnston discuss how tax has influenced snacks, beards, and even legends.
For additional coverage, read these articles in Tax Notes:
- James Bond Producers Offer New Clues on Mexican Incentives
- From Mexico With Love: How Sony Got Millions in Incentives to Rewrite 007 Film
- Sony E-Mails Show Plan to Exploit 'Loophole' in Expanded Film Credits
In the segment "In the Pages Sneak Peek," Tax Notes State Editor in Chief Jéanne Rauch-Zender talks with Marty Eisenstein about his piece, "Alexa, Is AI Taxable?"
This episode is sponsored by the Graduate Tax Program at LMU Loyola Law School in Los Angeles. For more information, visit www.lls.edu/taxnotes.
CreditsHost: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Allison Christians, the H. Heward Stikeman Chair in Tax Law at McGill University, tells Tax Notes contributing editor Robert Goulder about her proposal for a global excess profits tax as the third pillar in the OECD’s digital economy project.
For additional coverage, read her proposal in Tax Notes:
- It’s Time for Pillar 3: A Global Excess Profits Tax for COVID-19 and Beyond
For more background, read these articles in Tax Notes:
- OECD Postpones Key Meeting of Global Tax Overhaul Project
- Global Tax Reform Project Should Consider COVID-19, ICC Says
- G-20 Global Tax Revamp More Relevant Than Ever, Minister Says
- G-7 Ministers to Return to Digital Tax Agenda Once Crisis Slows
- World Must Not Lose Focus on Global Tax Overhaul, Germany Urges
All Tax Notes news coverage and analysis of the coronavirus pandemic is now free and accessible to the public: taxnotes.com/coronavirus-tax-coverage
Credits**Host: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Kate Kraus, a partner at Allen Matkins, tells Tax Notes legal reporter Eric Yauch the unexpected tax results of recent coronavirus legislation on real estate.
For additional coverage, read these articles in Tax Notes:
- IRS Provides Distribution Relief for REITs and RICs
- Substantive QIP Correction Answers Coming in Final Bonus Regs
- Some Taxpayers Would Rather Just Fix QIP Prospectively
- Bill Would Give O-Zone Treatment to Small Businesses Hit by Virus
- Loss Carryback Revival Could Prompt M&A Renegotiations
- O-Zone Investors Look for Additional Coronavirus Relief
In our new segment "In the Pages Sneak Peek," Tax Notes Executive Editor for Commentary Jasper B. Smith talks with Michael Q. Cannon about his recent piece, "Double Tax Benefits in the CARES Act."
All Tax Notes news coverage and analysis of the coronavirus pandemic is now free and accessible to the public: taxnotes.com/coronavirus-tax-coverage
Credits**Host: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Katie Quinn of McDermott Will & Emery LLP discusses the state tax implications of the COVID-19 pandemic with Tax Notes senior reporter Lauren Loricchio.
For additional coverage, read these articles in Tax Notes:
- Telework Could Trigger Withholding Changes in Some States
- CARES Act Could Compound 163(j) Issue for Separate Filers
- State Bills Would Clarify Exemption of Federal Stimulus Checks
- With Tax Deadlines Extended, States Offer Relief on Fines and Fees
- CARES Act Interest Limitation Relief Could Have State Tax Effects
- States Could See Revenue Losses Under Federal Stimulus Bill
All Tax Notes news coverage and analysis of the coronavirus pandemic is now free and accessible to the public: taxnotes.com/coronavirus-tax-coverage
Credits**Host: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
E. Martin Davidoff, the head of tax controversy at Prager Metis, discusses how the IRS and tax practitioners are handling tax changes and working from home as a result of the coronavirus pandemic with Tax Notes senior reporter Paul Jones.
For additional coverage, read these articles in Tax Notes:
- Business of Tax: The Strangest Filing Season in Memory
- IRS Phone Lines May Reopen as Agency Adjusts to ‘New Reality’
- IRS Opens the Floodgates on Tax Deadline Relief
- Law and Accounting Firms vs. COVID-19
- E-Services Help Desks Among Latest IRS Facilities Halted by Virus
In our new segment "In the Pages," Tax Notes Executive Editor for Commentary Jasper Smith discusses with contributing editor Ben Willis about his recently published article about former Vice President Joe Biden's COVID-19 tax plan.
All Tax Notes news coverage and analysis of the coronavirus pandemic is now free and accessible to the public: taxnotes.com/coronavirus-tax-coverage
Credits**Host: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Omri Marian, the academic director of the Graduate Tax Program at the University of California, Irvine, discusses his role in preparing the next generation of tax professionals and virtual teaching during the coronavirus pandemic with Tax Notes reporter Jonathan Curry.
For additional coverage, read these articles in Tax Notes:
- Virtual Paper Chase — Law Schools Transition to Online Classes
- Business of Tax: AI Brings Uncertainty and Opportunity to Tax Practice
- Business of Tax: International Tax, So Hot Right Now
- Business of Tax: The Emergence of the High-Tech Accountant
- Business of Tax: Why Aren’t Accounting Firms Hiring Accountants?
Credits**Host: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Mark Gasbarra, founder and national managing director of the firm Forte International Tax LLC, discusses how practitioners navigate the interconnected provisions of the Tax Cuts and Jobs Act with Tax Notes contributing editor Benjamin M. Willis.
In an extended edition of Coming Attractions, Tax Notes Executive Editor for Commentary Jasper Smith chats with Jeffrey Wong, professor and department chair in the Department of Accounting at the University of Nevada, Reno, about his upcoming article on how CPA firms are responding to the COVID-19 crisis.
Credits**Host: David D. Stewart
Executive Producers: Jasper B. Smith, Faye McCray
Showrunner: Paige Jones
Audio Engineers: Derek Squires, Jordan Parrish
Guest Relations: Nicole White
Nicole Kaeding, vice president of policy promotion and economist with the National Taxpayers Union Foundation, discusses the Coronavirus Aid, Relief, and Economic Security (CARES) Act.
For additional coverage, read these articles in Tax Notes:
- CARES Act Means Crunch Time for IRS and Treasury
- CARES Act Retirement Relief Appears Optional
- Coronavirus Relief Act Fixes NOL Legislative Quirks
- CARES Act Has Negative ‘Knock-On' Effects for International Tax
- Business of Tax: Planners Should Take Care Giving CARES Act Advice
- Trump Signs $2 Trillion Coronavirus Aid Bill
All Tax Notes news coverage and analysis of the coronavirus pandemic is now free and accessible to the public: taxnotes.com/coronavirus-tax-coverage
Martin Sullivan, the chief economist with Tax Analysts, says the U.S. is headed toward a recession unlike any other due to the economic fallout of the coronavirus pandemic and how to find relief.
For additional coverage, read these articles in Tax Notes:
- Economic Analysis: Emergency Tax Deferrals to Massively Boost Cash Flow
- Economic Analysis: Rx for the Coronavirus Economy
- News Analysis: Who Gets Emergency Paid Leave?
- Revisions to House Bill Scale Back Employee Paid Leave
- Emergency Legislation Mandates and Partially Subsidized Employee Paid Leave
All Tax Notes news coverage and analysis of the coronavirus pandemic is now free and accessible to the public: taxnotes.com/coronavirus-tax-coverage
Beverly Winstead, director of the University of Maryland’s Low-Income Tax Clinic, shares how the coronavirus pandemic has affected her as a practitioner and professor with Tax Notes Executive Editor for Commentary Jasper Smith.
For additional coverage, read these articles in Tax Notes:
- IRS Confirms: No April 15 Return Filing Extension
- Virtual Paper Chase — Law Schools Transition to Online Classes
- Still No Word From IRS on Virus-Affected Service Levels
- Tax Pros Skeptical of IRS Payment Deferral, but Welcome Relief
- Tax Pros Fear Procrastination, Workload From Filing Extension
- IRS Creates New Site for Coronavirus-Related Information
Tax Notes Today reporter Aaron Davis discusses the recent state efforts to clamp down on tax-incentive bidding wars by forming a multistate compact.
In the latest installment of Willis Weighs In, Tax Notes contributing editor Benjamin Willis discusses PLR 202009002 and its greater application.
For additional coverage, read these articles in Tax Notes:
- States Push for Cooperation Over Competition
- Connecticut Looks to Join Interstate Incentives Compact
- Questions Raised by Multistate Plan to Eliminate Incentives
- Rhode Island Lawmakers File Tax Incentive Compact Bill
- Arizona Bill Backs Interstate Tax Incentives Compact
- Kansas-Missouri Incentives War Ends in Truce
Eric Hylton, the new head of the Small Business/Self-Employed Division at the IRS, discusses employment tax, recent high-income nonfiler visits, and data analytics.
For additional coverage, read these articles in Tax Notes:
- IRS Expects to Hire 50 Percent More Collections Staff by Year’s End
- IRS Increases Effort to Fight Abusive Microcaptive Transactions
- IRS May Extend Microcap Settlement Offer to More Taxpayers
- IRS Looking for Promoter Links as Easement Crackdown Grows
- Enforcement Push Puts Taxpayer Rights at Risk, Olson Frets
- Officials Looking for Criminal Microcaptive Cases
- SB/SE Ramping Up Community Enforcement and Visibility
- Criminal Fraud Referrals to Get Bigger Focus in SB/SE
- IRS Leadership Shuffle Continues With New Division Chiefs
Yue “Daisy” Dai, a professor at the Shanghai University of Finance and Economics, describes life in China during the coronavirus outbreak.
She also discusses the tax policy measures the country is using to combat the pathogen. Read her piece published in Tax Notes.
For additional coverage, read these articles in Tax Notes:
- Hong Kong Proposes Waivers for Personal and Business Taxes
- Italy Delays Tax Payments for Area Under Coronavirus Quarantine
- China Announces Tax Measures in Response to Coronavirus
- Hong Kong Tax Agency Suspends Services Because of Coronavirus
In the latest installment of Willis Weighs In, Tax Notes contributing editor Benjamin Willis discusses the IRS's cryptocurrency guidance and its failure to properly address tax-free forks. Read his piece published in Tax Notes.
Damien Martin, CPA and host of the Simply Tax Podcast talks about the 2020 tax filing season.
For additional coverage, read these articles in Tax Notes:
- IRS Refund Fraud Progress May Be Undermined by Database Thefts
- TIGTA Spotlights IRS 2019 Filing Season Shortcomings, Successes
- Preparers Cautiously Optimistic for Normal 2020 Filing Season
- Once More Unto the Breach: 199A Filing Season Round 2
- It’s Dealer’s Choice With 163(j) for Filing Season
- Filing Season Opens January 27; IRS Releases Progress Report
Also, check out Damien's interview with Tax Notes Talk host David Stewart now on the Simply Tax Podcast.
Jason Furman, a professor at Harvard University and former chair of the Council of Economic Advisers, discusses the arguments used to back a wealth tax and suggests alternatives to reduce the wealth inequality gap in the U.S. with Tax Notes contributing editor Joseph J. Thorndike.
In the latest installment of Willis Weighs In, Benjamin Willis continues his vote-to-value disparity discussion by explaining how the value of vote can affect the value of other stock rights and classes of stock and the importance of appraisals .
For additional coverage, read these articles in Tax Notes:
- U.S. Wealth Tax Would Require More IRS Resources, Study Says
- Researchers Debate Need for Taxes That Wealthy Can’t Avoid
- Making a Wealth Tax Work May Require ‘Rough Justice’
- U.S. Well Positioned for Wealth Tax, Economist Says
- A Look Ahead: Democrats to Stand Behind Wealth Taxes in 2020
- Warren Takes on Economists Over the Effect of Tax Hikes
- Biden and Sanders Tax Plans Found to Overstate Revenue Gains
In honor of Tax Notes Talk’s 100th episode, we went back to the roots of what Tax Notes stands for: transparency.Tax Notes senior reporter Lauren Loricchio discussed her efforts to obtain the bid Indianapolis submitted to Amazon for HQ2 and Tax Analysts legal counsel Con Hitchcock shares the ensuing legal battle.
For additional coverage, read these articles in Tax Notes:
- Localities Dodging Open Records Laws to Avoid Disclosure of Amazon HQ2 Proposals
- Gary, Indiana Offered More Than $792 Million in Failed HQ2 Bid
- Chicago Offered More Incentives in Second HQ2 Selection Round
- Virginia Governor Signs HQ2 Incentives Package
- Amazon Reaffirms Commitment to Build HQ2 in Virginia
- Indiana Can Shield HQ2 Bid From Disclosure Under Advisory Opinion
Tony Nitti, a tax partner at RubinBrown LLP, discusses the final rules on Opportunity Zones and his observations of the program in action with Tax Notes senior legal reporter Stephanie Cumings.
For additional coverage, read these articles in Tax Notes:
- Confusion Looms About Which Set of O-Zone Regs to Apply
- Collateral Problems Could Arise From O-Zone Transition Rule
- O-Zone Regs Include Curveball on Improvements to Property
- O-Zone Investment Numbers Could Be Vast Underestimate
- O-Zone Safe Harbor Provision May Need Clarification
- O-Zone Rules Applicability Date Raises Dilemma for Investors
- Consolidated Group Rules Seen as Welcome Addition to O-Zone Regs
- Final O-Zone Regs Include Several Taxpayer Wins
In part 2 of her interview with Tax Notes senior reporter William Hoffman, former National Taxpayer Advocate Nina Olson discusses her ongoing fight for taxpayer rights and the upcoming fifth International Conference on Taxpayer Rights in South Africa.
For additional coverage, read these articles in Tax Notes:
- IRS Free Tax Return Preparation Remains Out of Reach
- Preparers See Benefits of Form 1040-SR, but Maybe Not for Them
- Politically Active Exempts May Have Escaped IRS Penalties
- A Look Ahead: Focus on Low-Income, ESL Taxpayers in IRS Overhaul, Advocates Say
- Enforcement Push Puts Taxpayer Rights at Risk, Olson Frets
Nina Olson, who retired as the National Taxpayer Advocate six months ago, talks about her new nonprofit and the need for Treasury to soon name her permanent successor.
This is part 1 of her interview with Tax Notes senior reporter William Hoffman.
For additional coverage, read these articles in Tax Notes:
- IRS Free Tax Return Preparation Remains Out of Reach
- Taxpayer Advocate Stresses Link Between IRS Enforcement, Service
- A Look Ahead: Focus on Low-Income, ESL Taxpayers in IRS Overhaul, Advocates Say
- Enforcement Push Puts Taxpayer Rights at Risk, Olson Frets
- Rettig Names Acting National Taxpayer Advocate
- Olson Bids Adieu, Leaving ‘Big Shoes to Be Filled’
In Willis Weighs In, Tax Notes contributing editor Ben Willis discusses vote-to-value disparity related to his article.
Tax Notes contributing editor Robert Goulder discusses the decades-old North American Free Trade Agreement (NAFTA), the new U.S.-Mexico-Canada Agreement (USMCA), and what these agreements mean for the future of tariffs and trade in North America.
Read Goulder's viewpoint on the subject: Hello, USMCA, Haven't We Met Before?
For additional coverage, read these articles in Tax Notes:
- USMCA Wins Overwhelming Approval in U.S. Senate
- U.S. Congress Looks to Roll Back Executive Tariff Authority
- Mexican Senate Passes USMCA With Little Opposition
- Tariff Threats Not a Roadblock to USMCA, Lighthizer Says
- USMCA Unlikely to Be Finalized in July, U.S. Senators Say
Reuven Avi-Yonah, a professor at the University of Michigan Law School, reviews the arguments raised in Altera v. Commissioner and predicts where the case might go with Tax Notes legal reporter Ryan Finley.
For additional coverage, read these articles in Tax Notes:
- A Look Ahead: High-Stakes Transfer Pricing Disputes to Continue in 2020
- IRS Will Continue Altera Fight in Other Circuits if Needed
- Ninth Circuit Rejects En Banc Review of Altera
- Ninth Circuit’s Altera Decision Didn't Cause a Circuit Split
- Altera Seeks Rehearing of Cost-Sharing Dispute
- Altera Beefs Up Legal Team in Cost-Sharing Dispute
Tax Notes's Jeremy Scott, Stephanie Cumings, and Andrew Velarde review what happened with tax legislation and guidance in 2019 and what lies ahead in 2020.
For additional coverage, read these articles in Tax Notes:
- Conservatives Worry TCJA Could Be Death Blow to Future Tax Cuts
- Senate Sends $426B in Tax Cuts to Trump's Desk
- A Look Ahead: Democrats to Stand Behind Wealth Taxes in 2020
- A Look Ahead: Eyes Still on TCJA International Guidance
- A Look Ahead: Parking Regs Should Address Fair Market Value
- A Look Ahead: Carried Interest and Form Changes Will Be Focus for Partnerships
Tax Notes reporters recount some of the quirkiest tax stories they encountered in 2019.
For additional coverage, read these articles in Tax Notes:
- Did World’s Oldest Woman Evade Both Death and Taxes?
- Horse Business Deductions Can’t Survive Dead Horse
- Arizona Governor Pulls Tax Breaks for Nike Over Canceled Shoe Line
- Executors Reap Millions in Fees on Tax Cheat Helmsley’s Estate
Tax Notes reporters Stephanie Johnston and Ryan Finley provide an update on the OECD’s work to find a multilateral solution on the taxation of the digital economy.
For additional coverage, read these articles in Tax Notes:
- U.S. Calls for Broader Scope, Narrower Nexus for Global Tax Deal
- EU Parliament Calls for One Voice in OECD Global Tax Talks
- OECD Aims to Publish Global Tax Reform Analysis in Early 2020
- Countries Fear Opportunity Cost of U.S. ‘Safe Harbor’ Proposal
- The U.S. 'Safe Harbor' Proposal: Rocking the OECD’s Pillar 1 Boat?
- Business Groups Urge Aggregate Approach to Pillar 2
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
Tax Notes chief correspondent Amanda Athanasiou discusses with Eversheds Sutherland partner Kriss Rizzolo the dearth of women in senior roles in tax law.
Rizzolo describes her own experience climbing the ladder and how to support other women who are doing the same.
For additional coverage, read Athanasiou's article in Tax Notes:
- Why Women Are Still Leaving Tax, and What to Do About It
In Willis Weighs In, Tax Notes contributing editor Ben Willis answers carried interest questions related to his article with Executive Editor for Commentary Jasper Smith.
Joe Myszka, a partner at DLA Piper, discussed the proposed rules on cloud computing transactions with Tax Notes legal reporter Kristen Parillo.
For additional coverage, read these articles in Tax Notes:
- Treasury Wants Input on Need for Cloud Transaction Sourcing Rule
- Practitioners Throw Shade at Cloud Regs' Digital Content Rule
- CPA Questions Scope of Cloud Computing Regs
- Treasury’s Proposal on Digital Content Sales May Cause Problems
- Proposed Regs Classify Cloud Computing Transactions
- OMB Completes Review of Cloud Computing Regs
- Sky Clears for Cloud Computing Regulations
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
Fasten your safety belts. Jeremy Cape of Squire Patton Boggs explains the U.K.’s Air Passenger Duty (APD) and one group’s proposal to impose a frequent flyer levy.
For additional coverage, read these articles in Tax Notes:
- Come Fly With Me, But Not Too Frequently
- German Airline Tax Prepared for Takeoff
- 9 European Countries Unite in Push for EU Aviation Tax
- Brazilian Government to End $18 Fee on International Flights
- Trade Group Advises Switzerland to Forgo Aviation Carbon Tax
In Willis Weighs In, Tax Notes contributing editor Ben Willis continues to discuss business purpose hurdles related to his article on the principle purpose threshold with Executive Editor for Commentary Jasper Smith.
Please reach out to Ben with questions at ben.willis@taxanalysts.org.
Scott Peterson — South Dakota’s former sales tax director and the Streamlined Sales Tax Governing Board’s first chief — discusses post-Wayfair issues, the current controversy in Kansas, and the gig economy with Tax Notes chief correspondent Amy Hamilton.
For additional coverage, read these article in Tax Notes:
- ACMA Compiling Remote-Seller Testimony to Spur Federal Legislation
- AICPA Paper Will Focus on Small Marketplace Seller Income Taxes
- Kansas Revenue Secretary: AG's Wayfair Opinion Creating Confusion
- Kansas Governor Brushes Off Objections to Wayfair Notice
- Kansas Attorney General Declares Void DOR’s Wayfair Approach
- Issues Over Wayfair Reference to ‘Undue Burden’ Coming to the Fore
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
Gabriel Zucman, an economics professor at the University of California, Berkeley, discusses wealth and inequality in America with Tax Notes contributing editor Nana Ama Sarfo.
He co-authored the book The Triumph of Injustice: How the Rich Dodge Taxes and How to Make Them Pay with Emmanuel Saez.
For additional coverage, read these articles and opinion pieces in Tax Notes:
- A Better Alternative to Wealth Taxes
- The Zucman Mandate: Life Without VAT
- Tax History: Saez and Zucman Exaggerate Redistributive Impulse in U.S. Tax History
- Wealth Tax Comparisons to Estate Tax ‘Not Fair,’ Panelist Says
- U.S. Well Positioned for Wealth Tax, Economist Says
- Economic Analysis: Risking the Wrath of 900 Billionaires
Tax Notes reporter Ryan Finely summarizes the OECD’s pillar 2 consultation draft and BDO’s Monika Loving provides her take on the proposal.
For additional coverage on pillar 2, read these article in Tax Notes:
- BEPS 2.0 Work Must Remove Unilateral Taxes, Tech Firms Tell OECD
- EU Divided Over GLOBE Minimum Tax
- OECD Calls for Design Advice on GLOBE Minimum Tax Proposal
- OECD’s Minimum Tax Work Has a Long Way to Go, Experts Say
- Agreement on BEPS 2.0 Expected in June 2020, OECD Tax Chief Says
- OECD Sets Course Toward Global Digital Tax Deal by 2020
In Willis Weighs In, Tax Notes contributing editor Ben Willis discusses business purpose and principle purpose threshold with Executive Editor for Commentary Jasper Smith.
For additional coverage on business purpose and principal purpose threshold, read these Willis Weighs In columns in Tax Notes:
- Principal Purpose: Treasury’s Disappointment in the TCJA
Martin Hearson, the international tax program lead at the International Center for Tax and Development, discusses how the OECD’s work on taxation of the digital economy affects developing countries.
Listen to our previous episode for a primer on Pillar 1 and the business perspective from EY’s Barbara Angus.
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
Former Tax Notes reporter Asha Glover interviews Jay Soled, a professor at Rutgers Business School, about his proposal for a value tax on publicly traded U.S. corporations. Soled co-authored the proposal in Tax Notes with Rutgers Business School Professor Dan Palmon.
Joseph Thorndike, director of the Tax History Project, explains the history of estate and inheritance taxes and how they became so unpopular.
For additional coverage, read these article in Tax Notes:
- Tax History: The Century of the Estate Tax: Made for Revenue, Not Redistribution
- Tax History: The Not-So-Puzzling Unpopularity of the Estate Tax
- Tax History: When Estates Were (Almost) Taxed as Income
Barbara Angus, global tax policy leader at EY, shares her thoughts on the OECD’s Pillar 1 consultation draft after Tax Notes chief correspondent Stephanie Johnston provides an update on its proposed profit allocation and nexus rules.
For additional coverage, read these article in Tax Notes:
- G-20 Ministers Call for Agreement on BEPS 2.0 Outline in January
- Agreement on BEPS 2.0 Expected in June 2020, OECD Tax Chief Says
- African Tax Officials Back OECD's Latest BEPS 2.0 Push
- OECD Proposal Leaves Taxpayers Anxious for Details
- OECD Unified Approach Proposes Sharp Break With Current System
- Certainty at Core of Digital Proposal, OECD Tax Chief Says
- OECD Sets Course Toward Global Digital Tax Deal by 2020
In part 2 of an interview with former IRS Commissioner John Koskinen, Tax Notes Today senior reporter William Hoffman and Koskinen discuss President Trump’s tax returns, transparency, and whistleblowers.
For additional coverage, read these article in Tax Notes:
- No Interview Yet Between Neal and IRS Whistleblower
- Treasury IG to Review Handling of Trump Tax Returns
- House Lawyers to Interview Trump Tax Audit Whistleblower
- Trump Audit Meddling Claim Deepens Questions About Whistleblower
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
In part 1 of an interview with former IRS Commissioner John Koskinen, Tax Notes Today senior reporter William Hoffman and Koskinen discuss IRS resources, enforcement, and taxpayer services.
For additional coverage, read these article in Tax Notes:
- IRS Rules New Cryptocurrency From Hard Forks Is Taxable
- IRS Exams Focus on EITC Claims, Not Poor, Inspector General Says
- IRS Budget Reduced Billions in Employment Tax Collections
- Small Business Enforcement Gets Fresh Focus From New IRS Bosses
Grace Perez-Navarro, the deputy director of the OECD’s Center for Tax Policy and Administration, discusses the findings of the organization’s recent report on tax morale—the willingness of companies and individuals to pay taxes—with Tax Notes Today International chief correspondent Stephanie Soong Johnston in London.
For additional coverage, read these articles in Tax Notes:
- OECD Highlights Taxpayer Morale as a Major Factor in Compliance
- Tax Morale Could Be Key to Domestic Resource Mobilization
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
Tax Notes Today State legal reporter Andrea Muse chats with Donald Williamson, the director of the graduate tax program at American University’s Kogod School of Business, about a New York resident tax credit case and his argument for the U.S. Supreme Court to hear it.
For additional coverage, read these articles in Tax Notes:
- New York’s Denial of Credit Is Unconstitutional, Taxpayers Argue
- New York Urges Supreme Court to Reject Resident Credit Case
- Organizations Urge Supreme Court to Hear New York Credit Case
- Taxpayers Ask Supreme Court to Review New York's Tax Credit Denial
- New York High Court Rejects Challenge to Credit Denial
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
Pascal Saint-Amans, the director of the OECD's Center on Tax Policy and Administration, shares the latest on efforts to address the tax challenges of the digital economy with Tax Notes Today International chief correspondent Stephanie Soong Johnston in London.
For additional coverage, read these articles in Tax Notes:
- Certainty at Core of Digital Proposal, OECD Tax Chief Says
- Unilateral Actions to Tax Digital Now Diluted, OECD Chief Says
- Ireland Can’t Rely on Its Tax Allure After BEPS 2.0, Group Warns
- U.S. and France Strike Compromise Over Digital Services Tax
- G-20 Leaders Greenlight OECD BEPS 2.0 Roadmap
- OECD Sets Course Toward Global Digital Tax Deal by 2020
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
Tax Notes Talk host David Stewart catches up with Jeremy Cape of Squire Patton Boggs in London about the current state of Brexit.
For additional coverage, read these articles in Tax Notes:
- The U.K. Conservative Party’s Paucity of Tax Policy Thinking
- Johnson’s Election Call Rejected as MPs Approve Brexit Bill
- MPs Win Control of Agenda in Move to Block No-Deal Brexit
- Johnson Defends Plan to Shut Parliament Weeks Ahead of Brexit
- U.K. Prime Minister-Elect Johnson Urged to Back Businesses
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
Tax Notes Today Federal reporters Jad Chamseddine and Asha Glover outline the tax issues Congress will likely tackle this fall.
For additional coverage, read these articles in Tax Notes:
- Stalled Retirement Bill Causing Frustration in Senate
- Task Force Results Shed Little Light on Extenders Future
- Debt Limit, Budget Caps Bill Heads to Trump’s Desk
- Gillibrand Drops Out of Presidential Race Ahead of Debates
- More Democratic Candidates Eye Capital Gains Tax Hike
Francois Chadwick, Uber’s vice president of finance, tax, and accounting, details the ride-sharing company’s proposal on international tax rules for the digital economy.
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
Tax Notes Today State reporters Lauren Loricchio and Aaron Davis recap the biggest tax trends to emerge from state legislatures in 2019 and preview what’s to come.
For additional coverage, read these articles in Tax Notes:
- Massachusetts Enacts Budget Revamping Remote Retailer Obligations
- Wisconsin Governor Signs Budget Including Income Tax Cuts
- Roundup: Marketplace Facilitator Laws Enacted in 33 States
- Illinois Lawmakers End Session With Tax Bills, Balanced Budget
- Illinois Graduated Income Tax Heads to Voters
- Minnesota Lawmakers Compromise on Federal Conformity, Tax Cuts
Francine J. Lipman, the William S. Boyd Professor of Law at the University of Nevada, Las Vegas, discusses her role as a Nevada state tax commissioner and her recent column in Tax Notes on U.S. Supreme Court Justice Ruth Bader Ginsburg’s pro bono tax work.
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
Tax Notes Today reporters Kristen Parillo and Jad Chamseddine discuss the Senate’s recent action on several tax treaties after a nearly decade-long delay.
For additional coverage, read these articles in Tax Notes:
- Senate Finishes Tax Protocols, Sets Sights on Treaties Next
- Senate Ratifies Spain Protocol, More to Come
- Senate Doesn’t Want Further Debate on Tax Treaties
- Tax Treaties Advance in Senate With Little Backlash
- Treaties Expected to Advance Despite Amendments Scare
- Negotiations Over Paul’s Hold on Tax Treaties Break Down
Tax Notes Today legal reporter Eric Yauch delves into the recent decisions by several private equity firms to convert to corporations in wake of the Tax Cuts and Jobs Act.
For additional coverage, read these articles in Tax Notes:
- Carlyle’s ‘Full C Corp’ Conversion Differs From Others
- Private Equity Firms Are Converting to Corps, Sort Of
- Apollo Joins Fund Manager Bandwagon by Converting to C Corp
- C Corp Conversions Advance, Others Still Mulling Decision
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
Tax Notes Today reporters Ryan Finley and Jad Chamseddine review several European countries’ unilateral approaches to taxing the digital economy and the U.S. reaction.
For additional coverage, read these articles in Tax Notes:
- France Confident of G-7 Digital Taxation Deal Despite U.S. Probe
- French Senate Passes DST Despite U.S. Tariff Threats
- U.K. Proposes Draft DST Legislation Containing Double Tax Relief
- Lawmakers Warn of Effect of Digital Services Tax on Trade Pacts
- Trump Orders Investigation of French Digital Services Tax
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
Jonathan Curry and Andrew Velarde discuss the draft regulations Tax Notes obtained from the Office of Information and Regulatory Affairs.
For additional coverage, read these articles in Tax Notes:
- New OIRA Drafts Reveal Tweaks to TCJA Guidance
- OIRA Leadership Shuffle Opens Door to Tax Reg Review Shake-Up
- OIRA’s Tax Reg Reviews Remain a ‘Black Box’ Despite Draft Regs
- Spotlight on OIRA’s Review Process Eases Politicization Concerns
- OIRA’s Imprint on Tax Regs Revealed in New Cache of Documents
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
Jared Dunkin, head of tax at a Washington, D.C.-based publicly traded multinational, discusses the role practitioners have in mentoring and developing tax professionals. Dunkin is author of the book, Brass Tax: 14 Actionable Insights to Power Your Success.
This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.
Steve Dixon and Kevin Kenworthy of Miller & Chevalier discuss the U.S. Supreme Court's recent decision to uphold Auer deference in Kisor v. Wilkie and what it means for the Treasury and the IRS.
For additional coverage, read these articles in Tax Notes:
- Auer Deference Survives, But ‘Neutered’ and ‘Zombified’
- U.S. Supreme Court Decision on Auer Won’t Affect Tax Cases
- Conservative Justices Question Feasibility of Auer’s Survival
- Gorsuch Dissent Could Signal Beginning of the End for Chevron
Kristen Parillo and Ryan Finley discuss the Ninth Circuit's new opinion in Altera v. Commissioner upholding a regulation requiring that parties to a cost-sharing arrangement share stock-based compensation.
For additional coverage, read these articles in Tax Notes:
- Altera, the Sequel — Jurisprudence Catches Up With BEPS
- Altera Decision Revives Commensurate With Income Standard
- Ninth Circuit Again Upholds Cost-Sharing Regs in Altera
Tax Notes Today State reporter Paige Jones discusses the developments in states since the U.S. Supreme Court's June 21, 2018, decision in South Dakota v. Wayfair Inc.
See the Tax Notes Nexus Tracker and these articles for more coverage:
- One Year Later: Experts Discuss Aftermath, Future Impact of Wayfair
- No New Streamlined Member States a Year After Wayfair
- NCSL SALT Task Force Contemplates Its Future Post-Wayfair
- Remote Sellers Seeking Relief as States Shift to Marketplace Laws
- New Hampshire Wages War Against Wayfair
Stephanie Johnston discusses the G-20 finance ministers' reaction to the OECD's workplan to achieve consensus on taxing the digital economy. The G-20 finance ministers met recently in Fukuoka, Japan.
For more coverage, read these articles in Tax Notes:
- G-20 Finance Ministers Endorse OECD Roadmap for Digital Economy
- France Aims for G-7 Consensus to Set Stage for Digital Tax Deal
- OECD Sets Course Toward Global Digital Tax Deal by 2020
- Countries Greenlight OECD Digital Tax Workplan
Professor Yair Listokin of Yale Law School discusses the ways that tax policy has affected past recessions and how it may help or hurt in the next one. He also takes a look at the Tax Cuts and Jobs Act from a macroeconomic tax perspective. Listokin is the author of the book, Law and Macroeconomics: Legal Remedies to Recessions.
Eric Yauch and Andrew Velarde highlight the major themes that came up at the American Bar Association Section of Taxation meeting in Washington, including interesting insights into recent and coming regulations.
For more coverage of the ABA meeting, read these articles in Tax Notes:
- IRS Considering More Safe Harbors in O-Zone Rules
- Partnerships Can Defer Section 1231 Gain Under O-Zone Rules
- Treasury Carefully Considering Interest Definition in Final Rules
- Triple Net Lease Changes Likely in Final 199A Safe Harbor
- IRS Won’t Be as Forgiving of TCJA Comment Deadlines
- Wilkins Predicts Temporary Regs Will Disappear From Rulemaking
- Treasury, IRS Open to Suggestions on PTI Simplification
- U.S. Officials Urging Delay of DSTs as Negotiations Continue
- Looming Tax Court Trial Will Test Economic Substance Doctrine
- Bridging the Guidance Enforcement Gap Is IRS Priority
Andrew Velarde talks to Joe Calianno of BDO about the pending final guidance on the global intangible low-taxed income provision enacted as part of the Tax Cuts and Jobs Act, and Paige Jones talks to Scott Smith of BDO about the state responses to GILTI.
At a breakfast panel of the American Bar Association Tax Section meeting in Washington, David Stewart talks to Lilian Faulhaber and Will Morris about the taxation of the digital economy. Lilian Faulhaber is a professor at Georgetown Law, and Will Morris is the deputy global tax policy leader at PwC.
Tax Notes Today Legal Reporter Eric Yauch discusses the final section 199A regulations and the IRS's FAQ on the application of the new passthrough deduction.
For additional coverage, read these articles in Tax Notes:
- IRS Sneaks ‘Nasty Surprise’ Into Expanded 199A FAQ
- Business Separation Under 199A Remains a Mystery
- Whether a Taxpayer Qualifies for 199A Depends on Who You Ask
- What Constitutes a Triple Net Lease for the 199A Safe Harbor?
- Rental Owners Realizing 199A Complexity as Filing Season Advances
- Separate Business Language Tweaked in Final 199A Regs
- Final 199A Rules Provide Answers to Some Structuring Questions
In a phone interview, Jonathan Curry talks to Brad Dillon of Brown Brothers Harriman about estate planning trends following the Tax Cuts and Jobs Act, as well aswhat keeps planners up at night ahead of the 2020 election.
Stephanie Cumings discusses the Opportunity Zone program and the highlights of the new proposed regulations.
For additional coverage, read these articles in Tax Notes:
- O-Zone Regs May Not Totally Bar Triple Net Leases
- O-Zone Regs Don’t Address Practical Tiered-Partnership Issue
- New Proposed O-Zone Regs May Be the Last, Officials Say
- Carried Interest Benefits Curbed for Some O-Zone Investments
In part 2 of an interview with National Taxpayer Advocate Nina Olson, Tax Notes Today senior reporter William Hoffman and Olson discuss her impending retirement, her work as the national taxpayer advocate, and her future plans.
In part 1 of an interview with National Taxpayer Advocate Nina Olson, Tax Notes Today senior reporter William Hoffman and Olson discuss the filing season, the Taxpayer First Act (H.R. 1957), the disclosure of program manager technical advice, and congressional efforts to get President Trump's tax returns.
For additional coverage, read these article in Tax Notes:
- Treasury Misses Dems’ Deadline for Handing Over Trump’s Returns
- House Approves IRS Reform Measure Despite Free File Fight
- Release of Emailed Chief Counsel Advice Dropped 17 Percent
- Taxpayer Advocate: IRS Using Email to Avoid Advice Disclosure
Raymond Wynman, the managing director of Global Tax Management’s International Tax practice, discusses the final rules on section 965, specifically the 965(b) basis-shifting election and the specified payment rule.
In our special April Fools' episode, Tax Notes reporters recount some of their favorite stories of tax protester arguments.
Stephanie Johnston talks to Grace Perez-Navarro, deputy director of the OECD's Centre for Tax Policy and Administration, about its public consultation in Paris to address taxing the digital economy, and Ryan Finley and Johnston discuss the consultation document in detail.
For additional coverage, read these articles in Tax Notes:
- Making Waves: OECD Navigates Debate on Tax Rules for Digital Age
- Simplicity Is Key in OECD Anti-Base-Erosion Proposal
- U.S.-Style Minimum Taxation May Spread Without OECD Coordination
- U.S., European Officials See Digitalized Economy Deal as Likely
- OECD’s Latest Digital Tax Consultation Draws Robust Response
- OECD Tax Proposals Tackling Digital Economy Draw Mixed Reactions
Mike Minihan of BX3 Capital discusses the cryptocurrency market and its regulatory and tax environment.
William Hoffman checks in on the the first round of tax filings under the Tax Cuts and Jobs Act, including the data on refunds and the effect of the government shutdown on the filing season.
For more detailed coverage, read these articles in Tax Notes:
- Refunds Turn Higher, but Treasury Warns of Changes
- Policymakers Debate Causes, Remedy for Tax Refund Lag
- Economic Analysis: Will Disappointing Refunds Derail the TCJA?
- IRS Recovery From Shutdown ‘Amazing,’ Rettig Says
- Don’t Blame Smaller Refunds on Withholding Tables, Says Treasury
- Tax Refunds Turn Into Political Football as Treasury Calls Foul
- Filing Season Stats Down Across the Board in First IRS Numbers
- Neither Bang Nor Whimper, Filing Season Starts With a Grind
Kimberly Clausing, the Thormund Miller and Walter Mintz Professor of Economics at Reed College, discusses tariffs, free trade, and globalization. She is also the author of the new book, Open: The Progressive Case for Free Trade, Immigration, and Global Capital.
Richard Joslin, a consultant to EnTrustPermal, discusses how the new business loss and interest expense limitations work together and affect other code provisions.
For more details, read Joslin's article in Tax Notes.
Carrie Elliot talks about the changes the Tax Cuts and Jobs Act will bring between now and 2027, including rate increases.
Eric Yauch discusses the final rules on the centralized partnership audit regime.
For additional coverage, read these articles in Tax Notes:
- Audit Regime Raises Need for Appeals Guidance
- Practitioners Suggest Options for Debt Issues in Audit Regime
- Final Audit Regs Put Focus on Debt Mischaracterization
- Final Audit Regs Clarify What’s In, What's Out of New Regime
- New Final Partnership Audit Rules Provide Several Clarifications
Tax Notes contributing editor Benjamin Willis examines the authority of regulators in interpreting statutory tax provisions, especially in the context of the Tax Cuts and Jobs Act as the role of regulations has become more prominent.
Read Willis’s related Tax Notes article.
Robert Goulder discusses the proposal to eliminate the EU's unanimity requirement for tax directives and what that would mean for tax policy.
For additional coverage, read these articles in Tax Notes:
- Should the EU Scrap the Unanimity Requirement?
- Cost of Unanimity on Tax Rules Will Only Increase, Group Says
- Proposal to End EU Unanimity Requirement Coming by Year-End
- EU's Moscovici Says Commission to Propose Qualified Voting on Tax Measures
- News Analysis: Is the End Near for the Unanimity Rule for EU Tax Issues?
Jonathan Curry takes a fresh look at the tax regulatory review agreement between the Office of Management and Budget and Treasury now that the process has had time to play out.
For further coverage, read these articles in Tax Notes:
- OIRA Review of Tax Regs Presses on Despite Shutdown
- A Look Ahead: Treasury, OIRA to Chart New Territory as Final Regs Flood In
- Treasury, OIRA Still at Odds Over When Tax Regs Merit Review
- Tax Regs Deemed Significant Skyrocket Under New Agenda
Jeremy Scott, Stephanie Cumings, and Andrew Velarde provide a review of what happened with tax legislation and guidance in 2018 and what's ahead in 2019.
For additional coverage, read these articles in Tax Notes:
- Neal Planning for TCJA Hearing by January’s End
- A Look Ahead: Legislators Queuing Up Multiple Retirement Bills
- A Look Ahead: Healthcare Tax Policy Could Stem From Divided Congress
- House Passes GOP Tax Bill With No Hope for Enactment
- A Look Ahead: Awaiting Clarification of 199A and Audit Regime Rules
- A Look Ahead: Questions Abound on Exec Comp Grandfathering Rule
- A Look Ahead: 2019 Should See Final Bonus and Tax Accounting Regs
In the second volume, reporters highlight the quirkiest tax stories of the year.
For coverage of these stories in Tax Notes, see:
- Meals Deduction Guidance Comes Off the Back Burner
- New Business Meals Guidance Creates Substantiation Concerns
- California Pot Money Takes Long, Strange Trip to Bank
- Historic $5.6 Million Washington State Tax Zapper Case Dismissed
- Cheesecake Factory Asks for Cherry on Top
Reporters highlight the quirkiest tax stories of the year.
As mentioned in the episode, here is a copy of Adolf Hitler's 1926 tax return provided to Tax Analysts.
For coverage of these stories in Tax Notes, see:
- Court Guns Down IRS Arguments Over Deductions for Cowboy Games
- Hitler’s 1926 Tax Return on Sale for $125,000
- Cirque du Soleil Founder’s Space Flight Taxable
Emily Foster and Eric Yauch discuss some of the key elements of the recently proposed regulations on the business interest deduction limitation.
For more extensive coverage, read these articles in Tax Notes:
- Interest Rule Leaves Securities Traders in a Jam
- Interest Regs Muddy Partnership Debt-Equity Decisions
- Interest Deduction Regs’ Antiavoidance Rule Causes Reassessments
- Interest Allocation Rules Could Wreak Havoc on Groups
- Interest Regs Require Taxpayers to Decide on ‘Early Adoption’
- Interest Regs Raise Same Real Estate Issues as 199A Rules
- Interest Deduction Regs Cover More Than Just Interest
- Interest Regs Tackle Some Passthrough Issues, Leave Others Open
David Stewart talks to Porus Kaka at the International Taxation Conference in Mumbai about various tax issues, including India's new permanent establishment concept, taxation of the digital economy, and the effects of the Tax Cuts and Jobs Act.
For related coverage, read these articles in Tax Notes:
- India’s Tax Chief: Digital Taxation Needs Fair Allocation Rules
- India’s New PE Scheme Limited by Unanswered Questions
- India Seeks Input on Digital PE for Taxing Foreign Companies
- India's Equalization Levy Brings In Nearly $90 Million
- India's 2018 Budget Introduces Digital PE Rules
Jad Chamseddine and Paul Jones discuss the Wayfair decision and the long-term implications for state and foreign taxes.
Listen to previous episodes on Wayfair:
- Navigating the Post-Wayfair World
- U.S. Supreme Court Overturns Quill
For additional coverage, read these articles in Tax Notes:
- Texas Bill Would Provide Statewide Local Tax Rate for Remote Sellers
- Wayfair Settlement Is a Missed Opportunity
- South Dakota and Wayfair Litigants Reach Settlement
- California Looks to Follow South Dakota on Remote Sales Tax Enforcement
- Alabama Remote Sales Tax Law Could Be Model for Other States
- California Likely to Implement Wayfair in 2019
- Beyond Wayfair: Implications for State and Foreign Taxes
Lauren Loricchio provides an update on Amazon's choice of two HQ2 locations: Northern Virginia and the borough of Queens in New York City.
For more coverage in Tax Notes, read:
- Louisville Won't Release HQ2 Bid, Despite Amazon Announcement
- Amazon's New York City HQ2 Site Eligible for Federal Tax Breaks
- Georgia First Also-Ran to Reveal Incentives Offered to Amazon
- Amazon to Split HQ2 Between New York City, Northern Virginia
- Group Slams Reports of Two Amazon HQ2s as 'Bait and Switch'
- Bezos Will Let His Heart Lead Him to Amazon's New Home
- Pittsburgh to Appeal Order Requiring Release of Amazon HQ2 Proposal
A roundup of the November 6 midterm election results. Asha Glover and Stephen Cooper discuss what changes to look for in the new Congress, including the makeup of the House Ways and Means Committee and the tax agendas. Paul Jones and Lauren Loricchio discuss the results in the state gubernatorial races as well as the tax ballot measures approved by state voters.
For more coverage in Tax Notes, see:
- Senators Agree on IRS Reform, Extenders as Lame-Duck Priorities
- Brady Eyes Dozens of TCJA Technical Fixes in Lame Duck
- Ways and Means to Review Tax Extenders This Week
- Tax Committees Brace for Turnover in Next Congress
- Trump Open to Corporate Rate Increase to Get Middle-Income Tax Cut
- Neal Wants Trump to Voluntarily Give Up Returns
- Gubernatorial Winners Set to Advance Tax Proposals
- Voters OK State Tax Ballot Measures on Marijuana, Income Tax Cap
- Midterms Stifle GOP Tax Plans as Democrats Take Control in House
Jonathan Curry discusses the IRS's rules addressing strategies using trusts to sidestep the section 199A deduction limitations and claim multiple deductions.
For more coverage in Tax Notes, see:
- 199A Regs’ Multiple Trust Rule May Invite Challenges
- Creating Just One Trust for the 199A Deduction? Think Again
- Non-Grantor Trusts Still Useful in TCJA Planning
- IRS Drops Hammer on 199A, SALT Cap Workarounds
- IRS Likely to Trounce 199A Trust Planning Strategy
Eric Yauch discusses a provision of the Tax Cuts and Jobs Act that hasn't received a lot of attention: section 461(l), which caps excess business losses at $250,000 for individuals and $500,000 for joint filers.
For more coverage in Tax Notes, see:
- New Loss Limitation Is on Government’s Radar
- New Loss Limitation Hard to Calculate, Interpret With Other Rules
Jeremy Cape of Squire Patton Boggs discusses the tax issues arising from Brexit.
For related coverage on Brexit, read these articles in Tax Notes:
- U.K. Tax is Lesser Concern in No-Deal Brexit
- U.K. Backs Customs Agents Facing Brexit Capacity Challenge
- EU, U.K. Leaders Willing to Extend Brexit Transition Period
- Brexit Talks at Impasse Over Customs Backstop Proposal
- EU Proposes 'Least Intrusive' Customs, VAT Checks After Brexit
- The U.K. Can’t Afford to Become a Tax Haven, Says Labour Politician
- EU Steps Up Complaint Against U.K. Over €3 Billion Customs Fraud
- HMRC Warns of Customs and VAT Impact of No-Deal Brexit
For more on the Jaffa Cakes and Pringles debate, see:
- Cake or Biscuit? Why Jaffa Cakes Excite Philosophers
- The Lord Justice Hath Ruled: Pringles Are Potato Chips
Andrew Breiner talks to practitioners about the various issues raised by state efforts to tax peer-to-peer car rentals.
For related coverage, read these articles in Tax Notes:
- Illinois Governor Vetoes Car Sharing Bill, Proposes Own Plan
- States Look to Tax the Car-Sharing Industry
- Airbnb and the Sharing Economy
Andrew Velarde highlights the significant insights from the recent American Bar Association Section of Taxation meeting in Atlanta, where the Tax Cuts and Jobs Act was once again the main topic of discussion.
For additional coverage of the ABA meeting, read these articles from Tax Notes:
- TCJA Shaping Global Discussion as Several Regs Near Completion
- U.S. Antiabuse Rules, Imperfect International Tax Regs Coming
- Transition Tax Guidance Will Extend Transfer Agreement Due Date
- 'Guideposts’ Revealed for R&D-intensive Business Spinoffs
- Treasury Clarifies 199A De Minimis Rules Have Cliff
- Rental Property Ownership Could Decide 199A Effects
- Treasury: Qualified Improvement Property Needs Technical Correction
- Bonus Depreciation Regs Unlikely to Be Finalized This Year
Amy Hamilton discusses the IRS's proposed regulations addressing workarounds to the cap on state and local tax deductions.
For additional coverage of the SALT regs, read these articles from Tax Notes:
- California Governor Vetoes SALT Deduction Cap Workaround
- New York Coalition to Fight Federal SALT Regulations
- The Frivolous Challenge to the SALT Deduction Cap
- Practitioners Urge Caution in Passthrough SALT Cap Planning
- New Jersey Won't Scrap SALT Cap Workaround, Despite IRS Regs
- Treasury Receives More Than 1,500 Comments on Proposed SALT Regs
- Proposed Federal SALT Rules Would Close Private School Donation Strategy
- IRS Has Plan to Shut Down SALT Workarounds
Andrew Velarde and Alexander Lewis provide an in-depth look into the proposed regs on global intangible low-taxed income.
Read Tax Notes’ latest coverage of the proposed GILTI regs:
- Treasury Assuages Some Concern Over GILTI Antiabuse Rule Breadth
- GILTI Regs Signal Business Interest Limits Might Apply
- Proposed GILTI Regs Could Result in Taxable Phantom Income
- Practitioners Bristle at GILTI Antiabuse Provision
- Practitioners Throw More Shade at GILTI Antiabuse Rules
- GILTI Regs Focus on Computations, Punt on FTC Issues
Stephanie Johnston, Robert Goulder, and David Stewart highlight the hot topics at the 72nd Congress of the International Fiscal Association recently held in Seoul.
Check out these stories for coverage of the 2018 IFA Congress:
- EU Digital Taxation Plan Is ‘Not a Master Thesis’
- OECD Makes Headway on Long-Term Answers to Tax Digital Economy
- OECD Finalizing Work to Enlist Digital Platforms to Collect VAT
- Judicial Oversight Important for GAAR Application, Judge Says
- Germany Wants Progress on BEPS, Minimum Effective Taxation
- EU Member States Remain Divided Over Digital Services Tax
Paige Jones talks to Jim Ford of Global Tax Management about how retailers are preparing to collect and remit sales and use taxes in the wake of the U.S. Supreme Court's decision in South Dakota v. Wayfair Inc.
David Stewart, Kristen Parillo, and Ryan Finley examine the Altera v. Commissioner case — everything leading up to the Ninth Circuit opinion, the withdrawal of the opinion by that court, and the status of the case now.
David Stewart and Eric Yauch delve into the details of the proposed regulations on the passthrough deduction under section 199A.
Jonathan Curry discusses the details of the new agreement between the Treasury Department and the Office of Management and Budget over authority to review tax regulations.
State Tax Notes Chief Correspondent Amy Hamilton examines the impact of federal tax reform on the states and how states are responding legislatively to the Tax Cuts and Jobs Act.
David Stewart and Ryan Finley discuss whether the Tax Cuts and Jobs Act will finally end the IRS's poor litigation record in transfer pricing cases.
Tax Notes Today Editor in Chief Brett Ferguson discusses where things are with the Tax Cuts and Jobs Act now that it's been six months since the law was enacted.
Jad Chamseddine talks to David Stewart about the U.S. Supreme Court's decision to overturn Quill in South Dakota v. Wayfair Inc. and the implications of that ruling for state tax collection on remote sales.
The director of the OECD's Center for Tax Policy and Administration, Pascal Saint-Amans, and the deputy director, Grace Perez-Navarro, sit down with Worldwide Tax Daily chief correspondent Stephanie Johnston to discuss the challenges arising from taxing an increasingly digital economy.
Andrew Velarde and David Stewart take a look back at the American Bar Association Section of Taxation May meeting and highlight the important guidance and developments that were discussed.
Andrew Velarde provides a preview of the upcoming American Bar Association Section of Taxation May meeting and the important guidance and developments that may be discussed.
Jonathan Curry and David Stewart discuss the tax planning opportunities and challenges arising from changes to the estate tax under the Tax Cuts and Jobs Act.
As tax day approaches, Tax Notes Today Editor in Chief Brett Ferguson discusses congressional efforts to reform the IRS, including the Taxpayer First Act and the 21st Century IRS Act.
In a special April 1 episode of the podcast, tax historian Joseph Thorndike and David Stewart discuss the intersection of U.S. taxes and alcohol.
Zoe Sagalow talks to David Stewart about the effect of the Tax Cuts and Jobs Act on law firms' tax practices. Her informal survey of law firms reveals they are already seeing signs of the new tax law spurring more demand for their services that could lead to increased hiring.
David Stewart talks to legal reporter Jad Chamseddine about the Wayfair case pending before the U.S. Supreme Court, which could overturn the Quill decision and lead to a major change in the taxation of online commerce.
David Stewart and Jonathan Curry discuss the complexity of measuring the impact of the tax cuts under the Tax Cuts and Jobs Act (P.L. 115-97).
David Stewart talks to Bill Parks and Reuven S. Avi-Yonah about taxing multinationals. They discuss the current state of the corporate income tax now that the Tax Cuts and Jobs Act is law and whether there is a better way to apportion income.
David Stewart talks to Lauren Loricchio about her effort to obtain through public records requests data from localities competing for Amazon’s second headquarters project. She found that the localities used various methods to avoid public disclosure of incentives offered to the company, including narrow interpretations of state open record laws and bids submitted through entities not subject to those laws.
David Stewart talks to Stephanie Johnston about the problem of taxing the digital economy and what the OECD and EU are doing to find solutions to the problem.
David Stewart, Jeremy Scott, and Emily Foster provide a legislative and regulatory preview of the year ahead now that tax reform has passed.
David Stewart and Jeremy Scott discuss the final version of the tax reform bill, which would permanently cut corporate taxes and temporarily provide relief for individuals through 2025.
David Stewart talks to Zoe Sagalow about a new estimate of inflation -- the chained consumer price index -- proposed in the House and Senate tax reform bills.
David Stewart talks to Jonathan Curry about Treasury’s removal of an analysis (Technical Paper 5) from its website on who bears the burden of the corporate tax.
David Stewart and Jeremy Scott discuss the details of the Senate version of the Tax Cuts and Jobs Act, highlighting the differences between the Senate and House bills. The modified mark of the Senate tax reform bill includes repeal of the Affordable Care Act's individual healthcare mandate and would make tax cuts for individuals temporary.
David Stewart and Jeremy Scott discuss the House Republican tax bill, the Tax Cuts and Jobs Act (H.R. 1).
David Stewart and Jonathan Curry discuss the budget reconciliation process and what it means for tax reform.
David Stewart talks to Jonathan Curry about the proposal in the “Big Six” tax reform negotiators' unified framework to tax passthrough businesses at a special rate.
David Stewart talks to Carrie Elliot, contributing editor at Tax Notes International, about carbon taxes and carbon pricing. They also discuss carbon taxes in the context of the Paris Agreement.
David Stewart talks to State Tax Today reporter Paige Jones about states pursuing alternatives to the gas tax.
Lauren Loricchio and Maria Koklanaris discuss the rollback of the Kansas governor's tax agenda, including ending the exemption for passthroughs.
Zoe Sagalow talks to Luca Gattoni-Celli about the data breach involving the IRS's data retrieval tool (DRT). After this episode was recorded, the IRS confirmed that its revised DRT was reactivated on October 1, 2017, for the 2018-2019 FAFSA form, but not for the 2017-2018 cycle. The IRS declined to provide any update about the timing or scope of the DRT's exploitation by identity thieves, including the number of victimized taxpayers. Tax Analysts will continue pursuing this story and share any new developments with our podcast listeners.