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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

ERC Updates: Handling the Flood of Improper Claims

Send us a text 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 Re...

May 03, 202424 min

Going to the Source: A New Approach to Personal Income Taxation

Send us a text 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 .” Follow us on Twitter: David Stewart: @TaxSte...

Apr 26, 202443 min

What the End of Chevron Deference May Mean for Tax

Send us a text 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 t...

Apr 19, 202428 min

Growing Deficit and the Future of U.S. Fiscal Policy

Send us a text 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 ." Follow us on Twitter: Martin Sullivan: @M_SullivanTax David Stewart: @TaxStew Tax Notes: @TaxNotes ** This episode is sponsored by the University of California Irvin...

Apr 12, 202425 min

The SEC’s Final Climate Disclosure Rules: Simpler but Disputed

Send us a text 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 ." 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 Pr...

Apr 05, 202416 min

What’s a U.S. Trade or Business? Analyzing YA Global

Send us a text 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 Follow us on Twitter: David Stewart: @TaxS...

Mar 29, 202433 min

Senate Stasis: An Update on Congress’s Tax Deal

Send us a text 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 Dea...

Mar 22, 202417 min

An Update on Pillar 1 Amount B

Send us a text 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 Z...

Mar 15, 202415 min

Navigating the Corporate Transparency Act

Send us a text 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 Repor...

Mar 08, 202426 min

Medtronic, 3M, Abbott Labs, Oh My! Transfer Pricing Update

Send us a text 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 Br...

Mar 01, 202439 min

Taxing Billionaire Borrowing: A New Kind of Wealth Tax?

Send us a text 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 . Follow us on Twitter: Robert Goulder: @RobertGoulder David Stewart: @TaxStew Tax Notes: @TaxNotes ** This episode is sponsored by the University o...

Feb 23, 202430 min

Tracking the Latest on the House Tax Reform Plan

Send us a text 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 Seekin...

Feb 16, 202420 min

The Plastic Problem: Using Tax to Protect the Environment

Send us a text 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 ." 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 TaxBandi...

Feb 09, 202433 min

Liberty Global and the Economic Substance Doctrine

Send us a text 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-Le...

Feb 02, 202416 min

What to Expect in the 2024 Filing Season

Send us a text 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...

Jan 26, 202433 min

Moore 2.0? Analyzing Altria Group Inc. v. United States

Send us a text 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 Moor...

Jan 19, 202421 min

Spotlighting Tax Transparency Around the Globe

Send us a text 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 mor...

Jan 12, 202417 min

State Tax Policy Trends to Watch in 2024

Send us a text 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 Clar...

Jan 05, 202431 min

2024 U.S. Tax Legislation Forecast

Send us a text 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 Cau...

Dec 29, 202336 min

Year-End Collection: Tax Oddities of 2023

Send us a text 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 Deduc...

Dec 22, 202322 min

A Recap of SCOTUS Oral Arguments in Moore v. United States

Send us a text 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 th...

Dec 15, 202330 min

The Reporter's Notebook: Stories From Covering the OECD

Send us a text 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 t...

Dec 08, 202319 min

Taxing Carbon at the Border

Send us a text 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 ...

Dec 01, 202314 min

Cryptoassets and State Taxation

Send us a text 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...

Nov 22, 202327 min

Taxing the Fast-Fashionistas

Send us a text 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 fraconfere...

Nov 17, 202318 min

Diversity and the Tax Bar

Send us a text 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 Trea...

Nov 10, 202318 min

Navigating New Guidance on the Corporate Alternative Minimum Tax

Send us a text 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 Deprecia...

Nov 03, 202337 min

IRA Energy Credits, Part 2: Proposed Regs and What’s Next

Send us a text 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: ...

Oct 27, 202338 min

IRA Energy Credits, Part 1: History and Early Guidance

Send us a text 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 Minimu...

Oct 20, 202332 min

The EU's Latest Plan to Simplify Corporate Taxation

Send us a text 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 Gro...

Oct 13, 202318 min
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