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Tax Notes Talk

Tax Noteswww.taxnotes.com
A discussion of cutting-edge developments in tax, including up-to-the-minute changes in federal, state, and international tax law and regulations.
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Episodes

Privacy vs. Policing: Treasury’s Tax Information Sharing Deal

Send us a text 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 Fil ing. " 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: Inves...

Jun 27, 202510 min

International Tax in the Reconciliation Bill: House Versus Senate

Send us a text 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 ...

Jun 20, 202522 min

In the Zone: Changes to Opportunity Zones in the House Budget Bill

Send us a text 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 Repub...

Jun 13, 202525 min

Past IRS Commissioners Analyze Agency Changes Under Trump

Send us a text 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 Uncle...

Jun 06, 202536 min

One Big Beautiful Bill: Breaking Down the House Tax Package

Send us a text 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...

May 30, 202519 min

The House Budget Bill’s Clean Energy Tax Credit Changes

Send us a text 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 Y...

May 23, 202529 min

Trump’s Tariff and Tax Policy 2.0

Send us a text 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...

May 16, 202547 min

Still at the Table: Updates on the OECD Global Tax Project

Send us a text 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 ...

May 09, 202512 min

IRS Automated Guidance: Pros and Cons

Send us a text 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 Artificia...

May 02, 202530 min

Budget Votes and Tax Cut Hopes: Congress's Path to Reconciliation

Send us a text 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 Budg...

Apr 25, 202518 min

Behind the Story: Investigating the Faults in the IRS’s FOIA System

Send us a text 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? Follow us on X: Amanda Athanasiou: @akathanasiou David Stewart: @Ta...

Apr 18, 202512 min

Trump, Tariffs, and Trade Turmoil

Send us a text 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 Follow us on X: Michael Smith: @TaxesMichael David Stewart: @TaxStew Tax Notes: @TaxNo...

Apr 11, 202529 min

Tax or Theft? Examining the History of the Property Tax

Send us a text 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 P...

Apr 04, 202541 min

Addressing Tax Policy Challenges for Workers With Disabilities

Send us a text 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 Co...

Mar 28, 202516 min

The Latest at the IRS: Personnel Changes, More Staff Reductions

Send us a text 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 Hu...

Mar 21, 202511 min

Corporate Transparency Act Update: Treasury’s Announcement

Send us a text 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 Focu...

Mar 14, 202528 min

Top Tax Cases of 2024, Part 3: C Corporations

Send us a text 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 Follow us on X: David Stewart: @TaxStew Tax Notes: @TaxNotes ** This episode is sponsored by the University of California Irvine School of Law Graduate Tax Pro...

Mar 07, 202539 min

Top Tax Cases of 2024, Part 2: S Corporations

Send us a text 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 Follow us on X: David...

Feb 28, 202547 min

Top Tax Cases of 2024, Part 1: Partnerships

Send us a text 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 Follow us on X: David Stewart: @TaxStew Tax Notes: @TaxNotes ** This episode is sponsored by ...

Feb 21, 202548 min

A Conservative Case for Taxing the Rich: Lessons From History

Send us a text 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...

Feb 14, 202528 min

Trump's Hiring Freeze and the IRS

Send us a text 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 F...

Feb 07, 202524 min

Former U.S. OECD Negotiator Talks Trump's Global Tax Impact

Send us a text 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, r...

Jan 31, 202529 min

How Monetizing Tax Data Puts Taxpayers at Risk

Send us a text 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 Follow us on X: Lauren ...

Jan 24, 202510 min

The Corporate Transparency Act: Recent Challenges and Confusion

Send us a text 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 Tran...

Jan 17, 202518 min

State Tax Policy Trends to Watch in 2025

Send us a text 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 Gr...

Jan 10, 202541 min

2025 U.S. Tax Legislation Forecast

Send us a text 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 Tru...

Jan 03, 202524 min

Year-End Collection: Tax Oddities of 2024

Send us a text 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 Sna...

Dec 27, 202432 min

Making Progress: Updates on the OECD Tax Reform Plan

Send us a text 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...

Dec 20, 202414 min

Planning for the Future: Succession in Tax Leadership

Send us a text 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 Ta...

Dec 13, 202422 min

Behind the Story: Investigating Private Placement Life Insurance

Send us a text 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 Caym...

Dec 06, 202415 min
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