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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

Tax Reform for the Digital Age

Send us a text 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 Sp...

Mar 23, 201923 min

The Cryptocurrency Market

Send us a text Mike Minihan of BX3 Capital discusses the cryptocurrency market and its regulatory and tax environment.

Mar 15, 201924 min

Tax Filing Season Update

Send us a text 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 S...

Mar 08, 201914 min

Tariffs, Free Trade, and Open Economies

Send us a text 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 ....

Mar 01, 201926 min

Business Loss Deduction Complications

Send us a text 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 .

Feb 22, 201922 min

TCJA Tax Rate Increases: What to Expect

Send us a text Carrie Elliot talks about the changes the Tax Cuts and Jobs Act will bring between now and 2027, including rate increases.

Feb 15, 20198 min

Final Audit Rules: Where Things Stand

Send us a text 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...

Feb 08, 201916 min

The Regulatory Power of the Executive Branch

Send us a text 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 ....

Jan 25, 201921 min

Tax Policy and the EU's Unanimity Requirement

Send us a text 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 ...

Jan 18, 201927 min

Revisiting the OIRA Reg Review Process

Send us a text 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...

Jan 11, 201915 min

The Year Ahead: Tax Legislation and Regulations

Send us a text 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 o...

Jan 04, 201923 min

Year-End Collection, Volume 2: Tax Oddities

Send us a text 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...

Dec 28, 201817 min

Year-End Collection, Volume 1: Tax Oddities

Send us a text 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...

Dec 21, 201813 min

Proposed Interest Regs: Key Details

Send us a text 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 Ad...

Dec 14, 201822 min

International Taxation Conference 2018: A View From India

Send us a text 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 Indi...

Dec 07, 201812 min

Beyond Wayfair: The Fallout

Send us a text 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 Sou...

Nov 30, 201818 min

Amazon Chooses HQ2 Locations

Send us a text 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...

Nov 22, 20187 min

The Midterm Elections: Implications for Tax Policy

Send us a text 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 ...

Nov 16, 201831 min

Multiple Trust Planning and 199A Regs

Send us a text 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...

Nov 09, 201812 min

Deciphering the New Loss Limitation Rules

Send us a text 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...

Nov 02, 20186 min

Brexit: The Tax Implications

Send us a text 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 Labou...

Oct 26, 201829 min

The Taxability of Peer-to-Peer Car Sharing

Send us a text 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...

Oct 19, 201814 min

ABA Meeting: Key Takeaways

Send us a text 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 'Guide...

Oct 12, 201810 min

An Overview of the Proposed SALT Regs

Send us a text 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 Tr...

Oct 05, 20189 min

Proposed GILTI Regs: The Details

Send us a text 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 ...

Sep 27, 201816 min

IFA 2018: The Highlights

Send us a text 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 Progr...

Sep 18, 201826 min

Navigating the Post-Wayfair World

Send us a text 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.

Sep 14, 201829 min

Altera: All You Need to Know

Send us a text 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.

Aug 31, 201813 min

Proposed 199A Regs: An In-Depth Overview

Send us a text David Stewart and Eric Yauch delve into the details of the proposed regulations on the passthrough deduction under section 199A.

Aug 17, 201816 min

Treasury-OMB Tax Reg Agreement

Send us a text 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.

Aug 10, 201816 min
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