Tax Notes Talk

Grace Perez-Navarro discusses her long career at the OECD Centre for Tax Policy and Administration and what’s next after her retirement. For additional coverage, read these articles in Tax Notes:Analysis: The OECD’s Push for Women Leaders in Tax TransparencyAnalysis: Grace Perez-Navarro — A Champion of Transparency and InclusionFollow 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/events.This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxplanning23.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Kyle Pomerleau of the American Enterprise Institute discusses the Biden administration’s fiscal 2024 budget and examines how the tax proposals play into the administration’s wider political agenda. For additional coverage, read these articles in Tax Notes:White House Budget Plan Targets Wealthy With Tax IncreasesTreasury Green Book Shows Few Major Changes in Tax Policy GoalsBiden Budget Would Raise Taxes on Wealthy to Save MedicareIn our “Editors’ Corner” segment, Amish Shah, a partner at Holland & Knight, chats about his upcoming Tax Notes column on the intersection of clean energy and tax. Follow us on Twitter:Alex Rifaat: @alexrifaatDavid 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 Practising Law Institute. For more information, visit pli.edu/taxplanning23.***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 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 SaysAnalysis: DSTs, Destabilization, and the Rocky Road to Pillar 1Netflix Tells OECD to Mull Cultural Levies for DST Rollback ListKenya Urges Narrower DST Removal Scope for Wider Tax Deal Buy-InOECD Consults on DST Rollback, Global Minimum Tax ImplementationU.K. Will Consider Extending DST if Pillar 1 Is DelayedFollow 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 Practising Law Institute. For more information, visit pli.edu/taxplanning23.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

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 ShortfallPrepare for the Biggest Tax Leadership Turnover EverHow an EY Split-Off Could Affect the U.S. Tax ProfessionTop Seven Reasons a Future Tax Leader Should Work in the OfficeFollow 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 Practising Law Institute. For more information, visit pli.edu/taxplanning23. ***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

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 IITransfer Pricing Litigation UpdateCoca-Cola Transfer Pricing Challenge FizzlesFor additional coverage, read these articles in Tax Notes:Analysis: 3M and the Renaissance of the Commensurate With Income StandardSupplemental Briefing Requested in Coca-Cola Transfer Pricing CaseTax Court Rejects 3M’s Challenge of Blocked Income RegsAnalysis: Brazilian Transfer Pricing Reforms Ease U.S. Tax FrictionsFollow us on Twitter:Ryan Finley: @ryanmfinleyDavid 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 and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

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 InvestigationsFirst Update to IRS’s Bank Secrecy Act Data Analysis Coming SoonIRS Criminal Investigators Want to Keep Talking About Bank DataIRS Looking for Real Tax Crime in Virtual RealityIRS Teams Collaborating to Thwart Emerging Cybercrimes and FraudCI Chief Has a Big Plan for How to Find Tax Dirty DeedsIn our “Editors’ Corner” segment, Sharon Katz-Pearlman, a shareholder with Greenberg Traurig’s global tax practice in New York, chats about her Tax Notes piece, "Definitely Not Boring: The U.N. Tax Committee and OECD Collide.”  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 and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

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 InequalityJury Is Still Out on Treasury Equity PlanListen 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 ConvolutedWealth, Inequality, and Taxes in the U.S.Feminism and the Tax CodeTaxes and the LGBTQ CommunityAddressing Racial Inequity in State and Local Tax PolicyThe Tax Code and Economic Justice in AmericaHow Racial Diversity Shaped U.S. International Tax PolicyFollow us on Twitter:Alex Rifaat: @alexrifaatDavid 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 and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

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.” Follow us on Twitter:Sarah Paez: @PaezWritesKiarra Strocko: @KiarraStrockoDavid 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 and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

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 NontaxationBiden Criticizes Republican Plans to Abolish IRSConservatives Say McCarthy Is Committed to National Sales Tax VoteFollow us on Twitter:Doug Sword: @doug_swordRobert 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 360 Coverage Pros. For more information, visit 360coveragepros.com/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

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: @MullaneyWritesDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the District of Columbia Bar Taxation Community. For more information, visit https://site.pheedloop.com/event/TaxConference2023/home/?utm_source=TaxNotes&utm_medium=Banner&utm_campaign=TaxConference&utm_id=TaxConference.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 360 Coverage Pros. For more information, visit 360coveragepros.com/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

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 AuditsNearly 6,000 Pages of Trump Returns Released, but Not IRS FilesTrump and His Tax Returns Likely Fodder for Next CongressJCT: Audit of Trump Returns Relied on Accuracy of Paid PreparersWays and Means Votes to Release Trump Tax InformationFollow us on Twitter:Joe Thorndike: @jthorndikeDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the District of Columbia Bar Taxation Community. For more information, visit https://site.pheedloop.com/event/TaxConference2023/home/?utm_source=TaxNotes&utm_medium=Banner&utm_campaign=TaxConference&utm_id=TaxConference.This episode is sponsored by the Tax Attorney Recruiting Event. For more information, visit the-tare.com.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 and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

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 FilesEV Credit Guidance Buys Time for Automakers on Battery RulesInitial Guidance Limits Buyback Tax on M&A Deals to BootCorporate AMT Guidance Provides Safe Harbor and Some ReliefA Look Ahead: After Policy Wins, White House Focus Turns to ImplementationFederal Tax Changes May Continue to Affect StatesFollow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the District of Columbia Bar Taxation Community. For more information, visit https://site.pheedloop.com/event/TaxConference2023/home/?utm_source=TaxNotes&utm_medium=Banner&utm_campaign=TaxConference&utm_id=TaxConference.This episode is sponsored by the Tax Attorney Recruiting Event. For more information, visit the-tare.com.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 and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

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, NOLsColorado Offers Millions in Incentives for Semiconductor Manufacturing CompanyIowa DOR Proposes Required Composite Returns for Passthrough EntitiesThrough the Looking Back: NYU Panelists Flag Multistate Issues for Year AheadOregon Business Interests to Seek Tax Incentives in 2023Follow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by SafeSend. For more information, visit safesend.com.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

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 PrisonColorado Now Accepts Cryptocurrency for Tax PaymentsHMRC Under Fire for VAT Bill on S’mores MarshmallowsListen to other tax oddities episodes:Year-End Collection: Tax Oddities of 2021Year-End Collection: Tax Oddities of 2020Follow us on Twitter:Emily Hollingsworth: @EmilyHoll9Kiarra Strocko: @KiarraStrockoDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by SafeSend. For more information, visit safesend.com.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

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 IssuesThe TCJA Five Years Later: Federal Tax IssuesFor additional coverage, read these articles in Tax Notes:Proposed Regs Target Consolidated Group CFC Income InclusionsAnti-Injunction Act Bars Silver’s GILTI Suit, Court FindsGovernment Pursues Liberty Global for $284 Million in DRD DisputeSpectrum Brands Files Protective Return After Liberty GlobalBiden Wants to Drop the BEAT and Replace It With Pillar 2Follow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the District of Columbia Bar Taxation Community. For more information, visit https://site.pheedloop.com/event/TaxConference2023/home/?utm_source=TaxNotes&utm_medium=Banner&utm_campaign=TaxConference&utm_id=TaxConference.This episode is sponsored by SafeSend. For more information, visit safesend.com.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

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 PackageYear-End Tax Title Still in Rumor RealmDems Ready to Deal; GOP Is a ‘Maybe,’ Former Top Pelosi Aide SaysLame-Duck Talks May Be Stalled Through December 6Lack of GOP Wave Dims Section 199A Permanence Chances, Group SaysResearch Amortization Procedural Guidance Expected This YearIn our “Editors’ Corner” segment, Michelle Markham, a professor at Bond University, chats about her Tax Notes column, Markham on Managing Disputes, and her latest installment, “Advancing Tax Certainty: The New OECD Bilateral APA Manual.” Follow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by SafeSend. For more information, visit safesend.com.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

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 SaysCalifornia Governor Signs SALT Cap Workaround FixPennsylvania Bill Would Create SALT Cap Workaround‘No SALT, No Deal’ Becomes No MoreFollow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by SafeSend. For more information, visit safesend.com.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 and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

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 UpdateThe End Is Nigh: An Update on the OECD Tax Reform PlanThe Beginning of the End? An Update on the OECD Tax Reform Plan For additional coverage, read these articles in Tax Notes:ECOFIN To Soon Try Again for Global Minimum Tax AgreementIndian Barrister Calls for Global Indirect Tax TreatyOECD Seeks to Improve CbC Reporting StandardU.K. Treasury Confirms Plan to Implement Pillar 2G-20 Heads Urge Countries to Finish Work on Pillar 1 Tax RulesGlobal Tax Deal Could Change Views on CCTB, EU Official SaysIn our “Editors’ Corner” segment, Naomita Yadav, a partner at Withers in San Francisco, chats about her Tax Notes column, (Tax) Matters of Life and Death, and her latest installment, “To PTE or Not to PTE: Estate Planning and SALT PTE Elections.” Follow us on Twitter:Stephanie Soong: @StephanieSoongDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by SafeSend. For more information, visit safesend.com.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 and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

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: @jthorndikeDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by 360 Coverage Pros. For more information, visit 360coveragepros.com/taxnotes.This episode is sponsored by SafeSend. For more information, visit safesend.com.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 and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

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: @mariesapirieDavid 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 SafeSend. For more information, visit safesend.com.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 and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart