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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

Bringing Order to Chaos? Digital Services Taxes and Pillar 1

Send us a text 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 Analysis: 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...

Mar 10, 202324 min

Paving the Way for the Next Generation of Tax Professionals

Send us a text 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 **...

Mar 03, 202330 min

IRS Victory: 3M Transfer Pricing Challenge Update

Send us a text 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 Cou...

Feb 24, 202317 min

Updates From IRS Criminal Investigation Deputy Chief

Send us a text 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 ...

Feb 17, 202347 min

Examining Treasury’s Review of Racial Bias in the U.S. Tax Code

Send us a text 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 Co...

Feb 10, 202329 min

Analyzing the Constraints of the OECD Corporate Mediation Process

Send us a text 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.” Fo...

Feb 03, 202329 min

A Closer Look at the National Sales Tax Proposal

Send us a text Tax Notes Capitol Hill reporter Doug Sword discusses the latest national sales tax proposal in Congress, and contributing 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: @Rob...

Jan 27, 202331 min

Teaching Tax Law Critically and the Earned Income Tax Credit

Send us a text 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...

Jan 20, 202339 min

Trump’s Tax Returns and the Future of Transparency

Send us a text 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...

Jan 13, 202333 min

2023 U.S. Tax Legislation Forecast

Send us a text 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, Whit...

Jan 06, 202325 min

State Tax Policy Trends to Watch in 2023

Send us a text 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 ...

Dec 30, 202230 min

Year-End Collection: Tax Oddities of 2022

Send us a text 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-E...

Dec 23, 202217 min

The TCJA Five Years Later: International Tax Issues

Send us a text 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-Inj...

Dec 16, 202239 min

The TCJA Five Years Later: Federal Tax Issues

Send us a text 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...

Dec 09, 202228 min

The TCJA Five Years Later: State Tax Issues

Send us a text 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: Davi...

Dec 02, 202230 min

Advancing the Pillars: An OECD Tax Reform Project Update

Send us a text 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...

Nov 23, 202226 min

The Case for Taxing Prison Labor

Send us a text 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 b...

Nov 18, 202231 min

Should We Have a Robot Tax? Part 2

Send us a text 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 Ta...

Nov 11, 202232 min

Should We Have a Robot Tax? Part 1

Send us a text 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, “ Tr...

Nov 04, 202233 min

IRS in Flux: New Funding and New Commissioner

Send us a text 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 a...

Oct 28, 202233 min

Updates From the Tax Court: Post-COVID Plans and New Funding

Send us a text 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 ...

Oct 21, 202235 min

Taking a Look Behind the Mic for Our Fifth Anniversary

Send us a text 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...

Oct 14, 202229 min

Assessing the New U.K. Leadership’s Unexpected Tax Changes

Send us a text 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...

Oct 07, 202233 min

The New Excise Tax on Corporate Stock Buybacks

Send us a text 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. Listen to our other episodes on the tax-related provisions in the Inflation Reduction Act: 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 ...

Sep 30, 202235 min

Transfer Pricing Litigation Update II

Send us a text 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 Med...

Sep 23, 202234 min

U.S. Tax Provisions Driving the Fight Against Climate Change

Send us a text 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 Assi...

Sep 16, 202233 min

$80 Billion in New Funding: What’s Next for the IRS?

Send us a text 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 Taxpayer...

Sep 09, 202239 min

The Unexpected Tax Consequences of Overturning Roe v. Wade

Send us a text 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...

Sep 02, 202226 min

Is IRS Tax Enforcement Colorblind?

Send us a text 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 ...

Aug 26, 202224 min

Analyzing the Corporate Alternative Minimum Tax

Send us a text 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 sur...

Aug 19, 202232 min
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