Tax Notes Talk

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_SullivanTaxDavid Stewart: @TaxStewTax 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 PLI Press. For more information, visit pli.edu/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

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_sarfoDavid Stewart: @TaxStewTax 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 PLI Press. For more information, visit pli.edu/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

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 GlobalTax Pros Weigh Impact of YA Global on Fund IndustryYA Global Footnote Shouldn’t Be OverlookedCayman Islands Hedge Fund Liable for Tax Bill of Over $57 MillionFollow us on Twitter:David Stewart: @TaxStewTax 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.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

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 SaysFinance Republicans Have Problem With Tax Bill’s Retroactivity Wyden Warns It’s Now or Never for R&D and Other Biz Tax BreaksLarger Priorities and Slow Discussions Leave Tax Bill in LimboTax Deal Doesn’t Have Support to Skirt Filibuster, Crapo SaysFollow us on Twitter:Cady Stanton: @cady_stantonDoug Sword: @doug_swordDavid Stewart: @TaxStewTax 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.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

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 DividesFor additional coverage, read these articles in Tax Notes:Amount B Transfer Pricing Approach Doesn’t Deliver, BIAC SaysAmount B Might Have a Phase 2, Bello SaysAmount B Won’t Change Australia’s Inbound Distributor ApproachNew Zealand Won’t Adopt Amount B Transfer Pricing FrameworkOECD Sets Out Amount B Transfer Pricing Simplification FrameworkAmount B Tax Certainty Is a Red Line for U.S., Bello SaysFollow us on Twitter:Stephanie Soong: @StephanieSoongDavid Stewart: @TaxStewTax 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.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

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 UnconstitutionalYellen: New Beneficial Ownership Reporting Rules Already WorkingFinCEN Finalizes Access Rule for Beneficial Ownership ReportingIRS Criminal Investigators Won’t Enforce New Transparency RulesFinCEN Finalizes Reporting Extension Rule Without More ReliefFollow us on Twitter:David Stewart: @TaxStewTax 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.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

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 3MMedtronic Budges on CUT Method in Round 2 at Eighth CircuitAbbott Labs Revives Fight Over Stock Options in Transfer PricingBlocked Brazilian Income Can’t Be Taxed in U.S., 3M Brief Argues3M Challenges Blocked Income Regs at Eighth CircuitGovernment Resumes Defense of Its Transfer Pricing for MedtronicCoca-Cola’s Brazilian Income Not Blocked, U.S. Tax Court SaysIn our “Editors’ Corner” segment, Edith Brashares, former director in the Treasury Office of Tax Analysis, chats about her coauthored Tax Notes piece, “Is the Economic Analysis Section of Regs Worth the Trouble?” Follow us on Twitter:David Stewart: @TaxStewTax 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.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

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: @RobertGoulderDavid Stewart: @TaxStewTax 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.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

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 VoteSmith Combats Claims Senate Republicans Weren’t in Tax TalksSenate Border Traffic Jam Pushes Tax Bill Back Weeks, at LeastHouse Tax Deal Vote Hasn’t Swayed Senators Seeking MarkupFollow us on Twitter:Cady Stanton: @cady_stantonDoug Sword: @doug_swordDavid Stewart: @TaxStewTax 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.For more information on Ask Blue J, visit bluej.com/ask. ***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

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: @TaxStewTax 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 TaxBandits. For more information, visit taxbandits.com and use promo code TaxNotes5.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

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 StatesMoore Money, More Tax Problems? Analyzing Moore v. United StatesFor additional coverage, read these articles in Tax Notes:ABA Section of Taxation Meeting: Liberty Global Is a Warning Against High-Level Business PurposeLiberty Global Appeals Economic Substance Loss to Tenth CircuitLiberty Global Promises Economic Substance Doctrine AppealEconomic Substance Doctrine Constrains Liberty GlobalFollow us on Twitter:David Stewart: @TaxStewTax 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 TaxBandits. For more information, visit taxbandits.com and use promo code TaxNotes5.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

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 MoratoriumIRS Launches Direct-File PlatformHopes for Senate Markup of Tax Deal Complicated by TimingIRS Unveils Sleeker Notices Ahead of Filing SeasonTax Deal Puts a Damper on Filing Season OptimismWerfel: Shutdown During Filing Season Could Be ‘Very Disruptive’Filing Season Tax Changes Could Be Challenging for Direct FileFollow us on Twitter:Jonathan Curry: @jtcurry005David Stewart: @TaxStewTax 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 TaxBandits. For more information, visit taxbandits.com and use promo code TaxNotes5.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

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 StatesMoore Money, More Tax Problems? Analyzing Moore v. United StatesFor additional coverage, read these articles in Tax Notes:Analysis: The Excise Power: Altria Waits Its TurnAltria’s Case Stayed Pending Realization Decision in MooreAltria Challenges IRS Downward Attribution Control AnalysisFollow us on Twitter:Robert Goulder: @RobertGoulderDavid Stewart: @TaxStewTax 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 TaxBandits. For more information, visit taxbandits.com and use promo code TaxNotes5.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

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 TransparencyFollow us on Twitter:Nana Ama Sarfo: @nanaama_sarfoDavid Stewart: @TaxStewTax 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 the Tax Attorney Recruiting Event. For more information, visit the-tare.com.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

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 RevenueCOST Urges California High Court to Block Taxation of IntangiblesThe High Cost of Untaxed SalesSALT Cap Workarounds Are Not Always Beneficial, Practitioner SaysStakeholders: More Clarifications Needed for New Mexico's Digital Ad RulesVoters Reject Wealth Taxes in Texas, Approve Pot Tax in OhioNew and Revised Guidance on GILTI, FDII Available in New JerseyFollow us on Twitter:David Stewart: @TaxStewTax 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 the Tax Attorney Recruiting Event. For more information, visit the-tare.com.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

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 SaysA Look Ahead: If a Tax Package Materializes, Don’t Blink or You’ll Miss ItThe Biggest Implications of MooreIRS Looks to Procure AI Operations PlatformIRS Cautioned to Be Careful in the Face of ClawbacksRepublican Taxwriters Push for Expired TCJA Tax Provision WorkFollow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

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 ArrivedTax Wonk Calls Foul on Massachusetts Surtax After NBA Player DepartsTaxpayer Hits Sour Note in Quest to Protect Cello From IRS LevyForged Documents Shatter Iranian Seizure Deduction ClaimStrained Vacation Locales Embrace Tourism TaxesListen to other tax oddities episodes:Year-End Collection: Tax Oddities of 2022Year-End Collection: Tax Oddities of 2021Year-End Collection: Tax Oddities of 2020Follow us on Twitter:Caitlin Mullaney: @MullaneyWritesEmily Hollingsworth: @EmilyHoll9Sarah Paez: @PaezWritesDavid Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

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 NarrowMoore Sold Shares in Transition Tax Company for Big GainMoores Fire Back That Macomber Is Controlling, Not Mere DictumTransition Tax Drafter: Quit It With ‘Mandatory Repatriation Tax’Small Business Groups Enter the Moore Fray in Defense of the TaxMoore Amicus Offers Supreme Court Off-Ramp From Realization QueryMacomber Dictum Not Controlling in Moore, Government SaysListen to our previous Moore episode: Moore Money, More Tax Problems? Analyzing Moore v. United StatesTo hear the full oral arguments, visit supremecourt.gov/oral_arguments/argument_audio/2023 In our “Editors’ Corner” segment, Błażej Kuźniacki, senior manager at the International Tax Services at PwC Netherlands, chats about his Tax Notes piece, “Pillar 2 and International Investment Agreements: ‘QDMTT Payable’ Seals an Internationally Wrongful Act.” Follow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

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 SaysEU Won’t Introduce Pillar 1 Directive, Commission Official SaysCanada’s Position on Digital Tax Is Unchanged, Freeland SaysMore European Governments Propose Global Minimum Tax BillsKuwait Signs Up to OECD Inclusive Framework and Tax Reform PlanBelgium Sends Draft Pillar 2 Legislation to ParliamentCountries Are Still at Pillar 1 Negotiating Table, Corwin SaysListen to our 200th and 100th episodes:200 Episodes: Tax Notes Talk's Defining InterviewsTax Notes Goes To Court (Again)Follow us on Twitter:Stephanie Soong: @StephanieSoongDavid Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

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' CritiquesAustralia Considers CBAM in Carbon Leakage Measures ConsultationNorway Isn't Obligated to Implement EU CBAM, Government SaysEU Tax Commissioner Seeks to Reassure CBAM CriticsNon-EU Countries Push Back on CBAM at WTO ForumEU Adopts CBAM Reporting RequirementsEU Wants Input on CBAM Phase-In RulesEuropean Parliament Approves Carbon Border Adjustment MechanismFollow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the Tax Attorney Recruiting Event. For more information, visit the-tare.com.This episode is sponsored by the FRA Private Investment Fund Tax & Accounting Forum. For more information, visit fraconferences.com/pif.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart