Talking Tax

Republicans on Capitol Hill are keenly watching how other countries implement a long-sought OECD agreement that exempts US companies from parts of the global minimum tax framework. Rep. Ron Estes (R-Kan.), a member of the tax-writing House Ways and Means Committee, hasn't ruled out resurrecting legislation imposing retaliatory taxes on firms from nations that slow-walk codifying the deal. The deal was reached earlier this month after the Trump administration demanded a carve-out for American companies and for the US tax system to work alongside the global minimum tax framework without interference. Estes sat down with Bloomberg Tax Congress reporter Zach C. Cohen in his Capitol Hill office to talk about the importance of the agreement to American businesses and how he will "trust, but verify" other countries' tax code changes, especially if they pursue the same kind of exemption Washington just secured. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The OECD just published the parameters of a deal that would exempt US companies from two key enforcement rules in the global minimum tax framework. The deal, which spans 88 pages in the form of administrative guidance, includes a slew of safe harbor rules that address everything from how US companies can get the exemption to more advantageous treatment of substance-based tax incentives like the US R&D credit. It includes a permanent, simplified global minimum tax calculation. Other countries would be able to obtain carve-outs like the ones obtained by the US and its multinational companies—if they meet certain criteria. This week on Talking Tax, reporters Lauren Vella and Somesh Jha discuss why the deal and the timing of its release is important, what it means for multinational businesses, how key US lawmakers reacted, and what the deal means for the efficacy of the global minimum tax going forward. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

We're off for the New Year holiday, so we're serving up an encore presentation of a Talking Tax podcast about challenges with paying student athletes. Ever since student athletes gained the right to be compensated for use of their image in advertisements and merchandise sales, the money has flooded in, but so have some problems. The athletes can now be compensated for their name, image, and likeness—or NIL—but schools still can’t directly pay them for playing. Instead, athletes can receive compensation when merchandise with their name or number is sold, or for showing up in advertisements or social media posts for businesses. But the line between legitimate NIL and illegitimate pay-for-play can get blurry. On this episode of Talking Tax, University of Kentucky professor Stephen Lusch talks with reporter Caleb Harshberger about how transfer pricing and tax law concepts can show whether the deals are done at reasonable prices that really reflect the value the student brings. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

PwC's new training program aims to give early-career recruits hands-on experience integrating artificial intelligence tools into everyday work. The Big Four accounting and advisory firm started piloting AI immersion sessions in October, with a full rollout to new US associates slated for July. The sessions are happening across PwC's tax, assurance, and advisory business. "We truly believe that the role of the new associate will be changing with AI and that their role will become somewhat elevated, and we need to make sure that we're really training them on those skills to work and think differently," said Margaret Burke, the firmwide talent acquisition and development leader for PwC US. Like its competitors, PwC has recently funneled resources into next generation autonomous tools aimed at handling routine tasks solo. The firm said in November it shed about 150 jobs across marketing, human resources, and other US support roles as part of a longer-term effort modernizing its back-office unit, including through using new AI tools. In this week's Talking Tax, Burke and PwC US Tax Leader Krishnan Chandrasekhar sat down with Bloomberg Tax reporter Jorja Siemons to discuss how the AI trainings have gone so far and what skills they hope new employees learn. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

A slew of big tax disputes and the worldwide upheaval brought on by the Trump administration's aggressive trade policy made for an exceptionally interesting year for transfer pricing professionals, and left them with lingering questions heading into 2026. President Donald Trump's April tariff announcements sent shock waves through the global economy and forced corporate tax heads—and C suites—to start figuring out what it all meant for their tax and transfer pricing positions, and whether they needed to make changes to fend off potential audits. At the same time, companies are seeing a growing number of audits and transfer pricing disputes—often with big dollar figures—as tax authorities around the world beef up their auditing and enforcement capabilities with staff, AI, and stronger reporting requirements. Auditing multinationals can bring them big tax rewards. That might be less true at the IRS, where the Trump administration has drastically reduced resources and staffing. On this episode of Talking Tax, Bloomberg Tax transfer pricing reporter Caleb Harshberger discusses what's been going on in the world of transfer pricing—which governs transactions within corporate groups—and what he's keeping an eye out for next year. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Anyone thinking about pushing the boundaries of tax law should remember that there's no federal statute of limitations on prosecuting fraud, even with weakened IRS enforcement, said Carolyn Schenck, who spent 20 years at the agency primarily combating tax evasion. "If people think that a current administration or a past administration might go soft on tax fraud, that's still an awfully big gamble," said Schenck, who's now at Caplin & Drysdale. "And I know that that's not one I personally would want to take." The IRS is coming off a tumultuous year with deep staffing cuts from the Trump administration's efforts to downsize the federal government and a parade of new commissioners. But increasing IRS staff and resources would be one of the best ways the government could combat fraud and collect more of the money it's owed, Schenck said. On this episode of Talking Tax, Schenck sat down with Bloomberg Tax reporter Erin Schilling to discuss what Trump administration workforce cuts mean for IRS enforcement and how the agency could improve its efforts to go after illegal tax shelters, even with a diminished staff. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

For the holidays, we serve up an encore presentation of a Talking Tax podcast that shows cross-border tax fraud has been around a long time. When researchers studied a previously mislabeled scroll, they discovered detailed attorney notes for a case against taxpayers accused of using forged documents and sham transactions between the Roman provinces of Judaea and Arabia to escape taxes on their assets. The assets in question were enslaved people. The potential punishments included distinctly unmodern measures. Anna Dolganov of the Austrian Academy of Sciences talked with reporter Caleb Harshberger about how scholars made the discovery, details of the scheme, and what they’re hoping to uncover next as they continue their research. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Congress is back after ending the longest shutdown in US history. But the bipartisan accord left funding for the IRS and Treasury Department ending in less than three months and the fate of the enhanced premium tax credits at the center of the crisis still unresolved. On this episode of Talking Tax, Bloomberg Tax Congress reporter Zach C. Cohen and Bloomberg Government health policy reporter Erin Durkin discuss next steps for appropriating funds for the IRS and Treasury after current funding runs dry Jan. 30, and potential legislative solutions to rising health-care premiums. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

New York City Mayor-elect Zohran Mamdani ran on an expansive affordability agenda that would be paid for by higher taxes on corporations and wealthy individuals. The democratic socialist's vision will be tough to realize, though, because any tax hikes would have to be approved by the New York State legislature and tax hike-averse Gov. Kathy Hochul (D). Local tax practitioners are emphasizing this political reality to worried clients who called and emailed in a hurry after Mandani won the Nov. 4 mayoral contest. “There’s been kind of some demystifying as to how can or how will the mayor be able to make these ideas or proposals law," Jeremy Gove, a state and local tax counsel at Eversheds Sutherland, tells Bloomberg Tax editor Benjamin Freed on this week's episode of the Talking Tax podcast. "Explaining this to taxpayers is what we’ve been tackling over the past week or so.” Gove says that while higher taxes could compel some New York companies and wealthy individuals to decamp for lower-tax states, there's also a "wait and see" sentiment prevailing. Taxpayers might even welcome some proposals from Mamdani, such as hiring more auditors to clear out the Department of Finance's hefty case backlog, he says. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Grant Thornton’s top audit leader is bullish on the practice’s future after a 2024 deal that sold a significant stake in the accounting and advisory firm to private equity investors led by New Mountain Capital. The audit practice has benefited from a boost in dedicated resources and also bolstered its safeguards against conflicts of interest. Those improvements stem from an operating contract between Grant Thornton’s legacy audit practice and its PE-backed business, said Ron Messenger, CEO of Grant Thornton’s audit business. The firm’s private equity deal ushered in a new two-part legal structure that created a corporate entity to provide its tax and advisory work while audit partners run the firm’s legacy assurance business. Nearly half of the largest 30 firms have cut PE deals and they all rely on what the industry calls the “alternative practice structure.” Underpinning that new operating structure is a services agreement spelling out the relationship between the two entities from governance to resources. Those agreements can’t be an afterthought, Messenger said. He spoke with Bloomberg Tax reporter Amanda Iacone about how Grant Thornton's services agreement came together, how regulators informed that document, and how it will influence the quality of the firm’s auditing. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

A Trump administration push to reduce the frequency of corporate earnings reports risks hurting the accuracy of artificial intelligence-fueled models used by analysts, an accounting adviser said. Chief financial officers and other C-suite leaders would in turn need to address greater reputational risk if a plan to give public companies the option to file financial reports semiannually instead of quarterly advances, according to Steve Soter, vice president and industry principal at financial compliance platform Workiva. Companies prepare and submit quarterly reports, called Form 10-Qs, to the Securities and Exchange Commission's filing system in XBRL format, which makes the information more easily accessible and computer-readable, Soter said. Analysts' models consume this data to provide analysis and observations. Depriving investors and analysts' AI models of this information increases the risk of erroneous analysis and ensuing reputational damage, Soter said. On this episode of Talking Tax, Bloomberg Tax financial accounting reporter Jorja Siemons spoke with Soter about what steps C-suite leaders can take to mitigate data risks if the SEC reporting schedule shifts. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Despite the ongoing US government shutdown, many at the Treasury Department remain on the job working on guidance related to the July GOP tax law. Those at Treasury handling the international provisions used to be coworkers of Beth Bell, who became a principal at PwC’s National Tax Service in Washington less than a month ago. On this week's episode of Talking Tax, Bell sat down with Bloomberg Tax senior reporter Chris Cioffi to discuss US efforts to secure agreements to allow the US tax system to coexist with the Pillar Two project, and what might prompt Republicans in Congress to reintroduce what came to be known as the "revenge tax" when the law was debated. Bell has deep experience with multilateral tax negotiations and worked as a staffer in both the House and Senate, playing a role in major tax legislation that passed in both the Biden and Trump administrations. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Ireland has presented a frugal budget for 2026 in the face of uncertainties caused by President Donald Trump's tariff and tax policies. The 15% global minimum tax on corporations and Trump's threats to impose large tariffs on pharmaceutical companies—most of which are US companies headquartered in Ireland—have increased pressure on the country to find ways to remain competitive. With foreign-owned multinationals in Ireland paying the majority of the country's corporation tax, the government is mulling incentives to encourage them to stay. In this episode of Talking Tax, Bloomberg Tax reporter Ryan Hogg discusses some options the government is considering, including an increase in the R&D tax credit. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Taxpayer advocates are keeping close watch on this week's decision to name Social Security Administration Commissioner Frank Bisignano as CEO of the IRS, and have many questions about what it could mean for the agency. Treasury Secretary Scott Bessent said Monday he was creating a new IRS CEO position, and Republicans in Congress seem to be generally supportive, though some said the White House should still name an IRS commissioner nominee. The Treasury Department assured staff in GOP Iowa Sen. Chuck Grassley's office that a commissioner nominee would still be sent to the Senate. At the same time, the Senate Finance Committee voted Wednesday to advance Derek Theurer's nomination to be undersecretary for legislative affairs and Donald Korb's nomination to be IRS chief counsel. That's good news for Pete Sepp —president of the National Taxpayers Union, a taxpayer advocacy group—who is concerned that many of the top IRS positions remained unfilled. Sepp, who sat down with Bloomberg Tax Senior Reporter Chris Cioffi for this episode of Talking Tax, said Congress is right to seek answers about how the CEO job interacts with the commissioner. He said he hoped the CEO position, in the future, would be selected by an IRS oversight board that has been dormant for more than a decade. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Ever since student athletes gained the right to be compensated for use of their image in advertisements and merchandise sales, the money has flooded in, but so have some problems. While the athletes can now be compensated for their name, image, and likeness—or NIL—schools still can't directly pay them for playing, and the NCAA has rejected any notion of "pay-for-play." Instead, athletes can receive compensation when merchandise with their name or number is sold or for showing up in advertisements or social media posts for businesses. But the line between NIL and pay-for-play can get blurry. A business owner who wants to support the team could overpay an athlete in an NIL deal, raising a question: Is it a bona fide business deal? On this week's episode of Talking Tax, University of Kentucky professor Stephen Lusch talks with reporter Caleb Harshberger about how transfer pricing and tax law concepts can help show whether the deals are done at reasonable prices that really reflect the value the student brings. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

About three months have passed since Treasury Secretary Scott Bessent announced that the US, along with its Group of Seven allies, agreed to work on a system that would exempt American companies from parts of the global minimum tax. In that time, the US proposed a technical solution to separate its tax system from the global minimum tax. But other countries have raised concerns about what the US position means for their own tax sovereignty and whether their companies will be left at a competitive disadvantage compared to their American counterparts. In this episode of Talking Tax, Bloomberg Tax reporters Saim Saeed and Lauren Vella hash out these countries' frustrations and discuss the feasibility of coming to an agreement on a "side-by-side" system by Dec. 31, the deadline suggested by the Trump administration. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Big job cuts and reductions in resources at the IRS are liable to prolong disputes over tax bills and force the agency to leave money on the table when cases are finally resolved. More than 170 attorneys have withdrawn from representing the IRS in cases in US Tax Court since Donald Trump became president in January, according to a Bloomberg Tax analysis. Many have quit the IRS altogether amid a major exodus of employees. Some Justice Department attorneys who represented the IRS in tax disputes in federal appeals courts have also left, moves that could impact some of the biggest, most prominent tax-related cases in the courts. The diminished resources suggest it’ll take longer to resolve cases, former attorneys and former IRS and DOJ officials say. The IRS may also be pushed into considering settlements in some cases where perhaps it wouldn’t otherwise. That would mean settling cases on less favorable terms for the agency, and potentially give taxpayers a leg up in dealing with the IRS. In this episode of Talking Tax, Bloomberg Tax senior reporter Michael Rapoport discusses the attorney departures and their implications, as well as attorneys’ frustrations about their jobs and fears about the future that prompted some to leave the IRS. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

President Donald Trump's widespread tariffs are boosting tax dispute risks for companies that are scrambling to understand how to factor the new trade duties into their transfer pricing and tax planning without attracting an audit. Tariffs raise the prices of imported goods, meaning companies importing products from their own affiliates may have to—or want to—adjust the pricing of those transactions to meet transfer pricing rules that require them to treat the deals as though they were done at arm's length, with unrelated parties. The added cost of the tariff will likely knock the pricing for many goods out of that arm's-length range, so companies may have to adjust these prices to stay compliant. Additionally, companies may be able to make adjustments to mitigate the tariff impacts by reducing the price the US entity pays for the good. These adjustments can attract scrutiny, however, from both tax and customs agencies. And growing geopolitical tensions may make it hard for companies to rely on tax dispute resolution mechanisms like mutual agreement procedures. In this episode of the Talking Tax Podcast, Crowe LLP transfer pricing practice leader Sowmya Varadharajan talked with reporter Caleb Harshberger about the choices, and risks, companies are facing. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Tax preparers consider themselves foot soldiers on the front lines of Americans' income tax preparations. They provide advice and file the returns, helping the government collect its revenue and make sure people are paying their fair share. They are also some of the first to warn taxpayers about scams. This group of preparers includes enrolled agents, who are the only federally licensed tax practitioners.  Enrolled agents now are assessing what the recent exodus of thousands of IRS workers and agency leadership means for filing season. They're also watching for guidance for how to implement new policies from the massive 2025 GOP tax law. Bloomberg Tax’s Erin Slowey spoke with Jennifer MacMillan, president of the National Association of Enrolled Agents, about rules related to overtime and tips from that new tax law, the regulation of tax preparers, and what happens next at the IRS as its workforce has been slashed. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Congress is back in session with just a few weeks to reach an agreement before government funding runs out Sept. 30. For IRS watchers, the lack of agreement on how to fund the tax collection agency or whether to extend expiring tax breaks rank among the key issues lawmakers will grapple with over the coming months. In this week’s episode of Talking Tax, Bloomberg Tax reporter Zach C. Cohen and Bloomberg Government reporter Maeve Sheehey preview the government funding fight and potential movement on budget reconciliation bills, and the impact on tax policy and administration. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.