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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

A Conversation with Former IRS Commissioner John Koskinen: Trump and Transparency

Send us a text 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 Whistleblo...

Oct 18, 201922 min

A Conversation with Former IRS Commissioner John Koskinen: Tax Administration

Send us a text 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 ...

Oct 11, 201925 min

From London: An Inside Look at the OECD’s Tax Morale Report

Send us a text 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 Resour...

Oct 04, 201918 min

‘Son of Wynne’ and the Fight over Resident Tax Credits

Send us a text 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 Cour...

Sep 27, 201910 min

From London: OECD Update on BEPS 2.0

Send us a text 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...

Sep 20, 201924 min

From London: Brexit Update

Send us a text 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 Busine...

Sep 13, 201921 min

Back in Session: Congress's Next Tax Moves

Send us a text 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...

Sep 06, 201913 min

Uber’s Solution to Taxing the Digital Economy

Send us a text 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 ....

Aug 30, 201921 min

Tax Trends in State Legislatures

Send us a text 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 Gradua...

Aug 23, 201910 min

A Conversation with Francine Lipman: Nevada Tax Commissioner, Pro Bono Advocate

Send us a text 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 ....

Aug 16, 201922 min

Tax Treaties Progress After Long Delay

Send us a text 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 Negotiat...

Aug 09, 20198 min

Private Equity Firm Conversions In A Post-TCJA World

Send us a text 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 sponso...

Aug 02, 201910 min

The Digital Services Tax: European Developments and U.S. Backlash

Send us a text 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 Orde...

Jul 26, 201912 min

Behind the Scenes of OIRA and Draft TCJA Regs

Send us a text 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 o...

Jul 19, 201921 min

Professional Development in Tax

Send us a text 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 ....

Jul 12, 201915 min

U.S. Supreme Court Upholds Auer Deference, With Limitations

Send us a text 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 En...

Jul 03, 201926 min

Altera, Again

Send us a text 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...

Jun 28, 201912 min

Wayfair: One Year Later

Send us a text 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 ...

Jun 21, 201913 min

G-20 Meeting: OECD Digital Economy Taxation Update

Send us a text 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...

Jun 14, 201911 min

The Economics of Tax Policy

Send us a text 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 ....

Jun 07, 201919 min

ABA Meeting: Key Insights Into TCJA Guidance

Send us a text 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...

May 28, 201913 min

GILTI and the State Responses

Send us a text 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.

May 23, 201928 min

Perspectives on the Taxation of the Digital Economy

Send us a text 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.

May 17, 201941 min

Final 199A Rules: What Now?

Send us a text 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 F...

May 10, 201914 min

State of the Estates

Send us a text 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 as what keeps planners up at night ahead of the 2020 election.

May 03, 201922 min

Opportunity Zone Program: A Primer

Send us a text 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...

Apr 26, 201911 min

A Conversation With the Taxpayer Advocate: Exit Interview

Send us a text 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.

Apr 19, 201943 min

A Conversation With the Taxpayer Advocate: Filing Season

Send us a text 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 Fig...

Apr 12, 201936 min

Final Transition Tax Regs: An Analysis of Important Changes

Send us a text 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.

Apr 05, 201913 min

Tax Conspiracy Theories

Send us a text In our special April Fools' episode, Tax Notes reporters recount some of their favorite stories of tax protester arguments.

Apr 01, 201924 min
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