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 SaysFollow 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

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 2027New Jersey Tax Division: Crypto, NFTs Are Financial ProductsNew York Attorney General Proposes to Tighten Crypto Industry RulesThe State of NFTs: Navigating the Taxation of Digital AssetsState Guidance on Cryptocurrency and NFTs Needed, Panel SaysFollow 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 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

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_sarfoDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the FRA Private Investment Fund Tax & Accounting Forum. For more information, visit fraconferences.com/pif.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

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 DiscriminationExamining Treasury’s Review of Racial Bias in the U.S. Tax CodeIs 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:Caitlin Mullaney: @MullaneyWritesDavid 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 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

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 SharesCorporate AMT Consolidation Rules Flow From Tax PrinciplesFinancial Firm Highlights Potential for Corporate AMT DistortionTreasury Official Explains Confusing Rule in Corporate AMT NoticeCorporate AMT Depreciation Tweaks Unsurprising but WelcomeGuidance Fills In Some Blanks on Corporate AMTFollow 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

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 ProcessEnergy Department Opens Portal for Low-Income Bonus Energy CreditAnalysis: Apprentices and Emergency RepairsAnalysis: For U.S. Territories, IRA Credits Remain a Complicated QuestionAnalysis: Proposed Labor Requirement Regs Contain Few SurprisesIn our “Editors’ Corner” segment, Michael Semes, professor of practice in the graduate tax program at the Charles Widger School of Law at Villanova University and of counsel at BakerHostetler, chats about his coauthored Tax Notes piece, “ADP Certiorari Denial Increases SaaS Uncertainty.” Follow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the University of Cincinnati. For more information, visit online.uc.edu/taxation.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

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 BuybacksU.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 TaxFor additional coverage, read these articles in Tax Notes:Analysis: Apprentices and Emergency RepairsAnalysis: For U.S. Territories, IRA Credits Remain a Complicated QuestionAnalysis: Proposed Labor Requirement Regs Contain Few SurprisesFollow 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 University of Cincinnati. For more information, visit online.uc.edu/taxation.This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxstrategies23.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

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 BEFITEuropean Commission Draws Lessons From Past Failures With BEFITBEFIT to Apply to Pillar 2 Groups, Align Transfer Pricing RulesEU Businesses Want More Involvement in BEFIT PreparationsFollow us on Twitter:Elodie Lamer: @ElodieLamerDavid 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 University of Cincinnati. For more information, visit online.uc.edu/taxation.This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxstrategies23.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Professor Jeremy Bearer-Friend of the George Washington University Law School discusses poll taxes in the 20th century and how they were used to target taxpayers based on race and ethnicity. For more, read Bearer-Friend's article, "Race-Based Tax Weapons."Listen to more Tax Notes Talk episodes from our critical tax theory series:Examining Treasury’s Review of Racial Bias in the U.S. Tax CodeIs 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:Joe Thorndike: @jthorndikeDavid 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 University of Cincinnati. For more information, visit online.uc.edu/taxation.This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxstrategies23.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Robert Kerr, formerly with the IRS and now with Kerr Consulting, discusses latest developments from the IRS, including the tax agency’s plans for a government shutdown and its handling of the employee retention credit. For additional coverage, read these articles in Tax Notes:Looming Shutdown Threatens to Derail IRS’s ProgressIRS Isn’t Shutdown-Proof After AllIRS to Scale Back EITC Audits, Citing Racial DisparitiesNTEU: IRS’s Push to Hire 3,700 Auditors Is Doable but DifficultIRS Floats Adding Partnerships to Prefiling Compliance ProgramIRS Hopes to Sic 3,700 New Revenue Agents on Big BusinessesIRS Halts ERC Claims Processing Amid ‘Tsunami’ of FraudFollow us on Twitter:Jonathan Curry: @jtcurry005David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxstrategies23.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Garrett Brodeur, a tax attorney based in Washington, D.C., discusses the recently released proposed regulations for the cryptocurrency industry and their potential effect on digital asset transactions. For additional coverage, read these articles in Tax Notes:Tax Pros Wary of Overly Inclusive Crypto Reporting RegsDecentralized Exchanges Considered Brokers Under Proposed RegsProposed Regs Provide Guidance on Digital Asset Sales and ExchangesFollow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxstrategies23.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Tax Notes reporter Andrew Velarde discusses the latest developments on the final regulations for claiming foreign tax credits, including the IRS’s decision to delay implementation and the tax community’s response. For more on the foreign tax credits, listen to "The Final Foreign Tax Credit Rules: Complaints and Confusion."For additional coverage, read these articles in Tax Notes:IRS Says It Anticipates Extending FTC Relief Notice Another YearTreasury to Publish FTC Guidance on Pillar 2 Taxes by Year-EndGOP Taxwriters to Air Grievances to OECD Leaders in EuropeSilicon Valley Asks IRS to Extend Foreign Tax Credit ReliefJohnson & Johnson Sees $500 Million Tax Benefit From FTC Reg DelayIRS Offers Temporary Relief From Foreign Tax Credit RulesIn our “Editors’ Corner” segment, Christopher Moran, counsel at Venable LLP in Baltimore, chats about his coauthored Tax Notes piece, “Proposed Energy Credit Regulations Limit Clean Energy Investment.” Follow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxstrategies23.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Professor Clint Wallace of the University of South Carolina School of Law discusses his argument for using tax policy to reinforce democracy.For more, read Wallace's article, "A Democratic Perspective on Tax Law."Follow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxstrategies23.***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 preview what to expect from Congress in tax policy this fall, from a potential end-of-year tax package to IRS funding. For additional coverage, read these articles in Tax Notes:GOP Taxwriters to Air Grievances to OECD Leaders in EuropeOnce Upon a Time: Bipartisan Senate Group OK’d $40B for IRSState SALT Workarounds Cost Feds at Least $10 Billion AnnuallyDemocrats Drew Line in Sand for IRA Provisions but Left IRS OutEndgame for Tax Legislation Extra Murky as Budget Impasses LoomR&D Expensing Revamp Tops Wish List for Year-End Tax TalksOne Year Later, IRA’s Clean Energy Credits Remain Unknown to ManyGOP SALT Cap Plans Overwhelmingly Benefit Wealthy, Report SaysFollow us on Twitter:Cady Stanton: @cady_stantonDoug Sword: @doug_swordDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxstrategies23.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

John McGowan of HubSync discusses artificial intelligence and its role in the tax field. For additional coverage, read these articles in Tax Notes:AI in the DOR: State Tax Departments Ponder Use of Artificial IntelligenceIRS Working to Deploy AI Algorithms and ModelsAI Programs Not Reliable Enough Yet for Tax Work, Attorney Says 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

Tax Notes contributing editor Ryan Finley provides an overview of amount B from pillar 1 of the OECD’s two-pillar corporate tax reform plan and discusses the fundamental dispute over it. For additional coverage, read these articles in Tax Notes:Analysis: Scoping-Criteria Dispute Overshadows Amount B ProgressAnalysis: OECD Agreement on Amount B Tax Deal Remains ElusiveFollow us on Twitter:Ryan Finley: @ryanmfinleyDavid Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Tom Cullinan, a former IRS official now with Chamberlain Hrdlicka, discusses the basics of the employee retention credit, the recent rise in misleading promotions and fraudulent ERC claims, and the IRS’s response.For additional coverage, read these articles in Tax Notes:Employee Retention Credit a ‘Great Concern’ for IRS, Werfel SaysIRS May Face Constraints in Quest to Curb ERC AbuseW&M Panel Considers Amnesty for Fraudulent ERC PaymentsWerfel Drops Hint, Seeks Early End to Employee Retention CreditIRS Zeroes In on Erroneous Employee Retention Credit ClaimsIRS Hard Line on ERC Eligibility Earns Kudos From Tax ProsPayroll Companies Likely Contributing to Mistaken ERC ClaimsIn our “Editors’ Corner” segment, Naomita Yadav, a partner at Withers in San Francisco, chats about her Tax Notes piece, “Sparing No One: Cross-Border Taxation of Globally Mobile Individuals,” the second in a two-part series. Follow us on Twitter:Caitlin Mullaney: @MullaneyWritesDavid 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 White House reporter Alexander Rifaat discusses the Biden administration’s economic plan called “Bidenomics” and its effect on tax.For additional coverage, read these articles in Tax Notes:National Economic Council Touts Impact of Biden Tax IncentivesBiden Extols the Virtues of ‘Bidenomics’Treasury Links Construction Surge to CHIPS and IRA CreditsFollow us on Twitter:Alex Rifaat: @alexrifaatDavid Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Manal Corwin, the new director of the OECD's Centre for Tax Policy and Administration, discusses her vision for the organization and the latest updates on the inclusive framework and two-pillar project. For additional coverage, read these articles in Tax Notes:Vietnam Proposes Global Minimum Tax Rules to Apply in 2024BIAC Calls for More Consultations on Global Minimum Tax RulesU.K. Adopts Accounting Standard Changes for Pillar 2 Tax RulesBeyond the Numbers: Another Look at the JCT Pillar 2 ReportDigital Taxes Won’t Go Away Anytime Soon, U.N. Official SaysAutonomous Business Activities Exempt From OECD Amount A Tax RulesOECD Seeks Simpler Transfer Pricing With Amount B ConsultationCountries Advance Pillar 1 Adoption, Extend Digital Tax FreezeFollow 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

Professor Hank Adler of Chapman University discusses the income realization requirement dispute in the transition tax case Moore v. United States before the Supreme Court, and its implications on the U.S. tax system. For additional coverage, read these articles in Tax Notes:News Analysis: Limiting the Fallout From MooreSupreme Court to Hear Transition Tax Case With Vast ImplicationsFollow 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

Marna Ricker, EY’s global vice chair of tax, discusses how international tax advisers and corporate tax clients have handled recent tax reforms and what to expect next. For additional coverage, read these articles in Tax Notes:Extended OECD Digital Tax Ban Will Hurt Canada, Freeland SaysCountries Advance Pillar 1 Adoption, Extend Digital Tax FreezeEuropean Tech Companies Push for EU Action on Digital TaxesAustralia Mulls More Pillar 2 Deferred Tax Break Disclosure RulesFollow 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

Professors Kathleen DeLaney Thomas and Erin Scharff discuss fake tax news and the effect it has on public policy. For more, read the professors' article "Fake News and the Tax Law."Follow us on Twitter:Robert Goulder: @RobertGoulderDavid Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Tax Notes reporters Cady Stanton and Michael Smith discuss the recently passed U.S.-Chile tax treaty and the importance of tax treaties on both a national and international scale. For additional coverage, read these articles in Tax Notes:Chile-U.S. Tax Treaty Gets Senate Approval, Heads to White HouseSenate Scheduled to Vote on Chile-U.S. Tax TreatyTreasury's Treaty Approach Seeks to Avoid Future ComplicationsIn our “Editors’ Corner” segment, George Jackson, a professor of management, business, and economics at Virginia Wesleyan University, chats about his Tax Notes piece, “Early History of the Deduction for Interest Paid.” Follow us on Twitter:Cady Stanton: @Cady_StantonMichael Smith: @TaxesMichaelDavid Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Steve Rosenthal of the Urban-Brookings Tax Policy Center reviews the GOP tax package approved by the House Ways and Means Committee, specifically the proposed individual and business tax cuts. For additional coverage, read these articles in Tax Notes:House Tax Bill Racing Toward Floor Vote but Has a SALT ProblemWays and Means GOP Votes to Advance Tax PackageGOP Introduces Tax Package to Kick Off Tax Bill NegotiationsHouse Tax Bill to Focus on TCJA ExtensionsFollow us on Twitter:Cady Stanton: @cady_stantonDavid Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Scott Peterson of Avalara discusses the South Dakota v. Wayfair decision, including how companies and states are faring five years later and what could be next with sales tax nexus. For additional coverage, read these articles in Tax Notes:Quad Graphics Urges Supreme Court to Take Up Sales Tax AppealSouth Dakota’s Deb Peters Discusses Wayfair Five Years LaterNo Need to Hear Sales Tax Dispute, North Carolina Tells SCOTUSHalstead Bead Asks Fifth Circuit for Relief From Louisiana's Tax SystemNorth Carolina Institute Urges SCOTUS to Hear Sales Tax DisputeArizona Lawmakers Consider Sales Tax Simplification BillPanelists: Post-Wayfair Nexus Thresholds, Retroactive Application Still Unresolved***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Tax Notes reporter Alexander Rifaat discusses the tax implications of the recently passed debt ceiling bill and gentleman’s agreement over IRS funding.For additional coverage, read these articles in Tax Notes:Biden Signs Debt Ceiling Bill Into LawSenate Approves Debt Limit Deal, IRS ClawbacksFreedom Caucus Voices Opposition to Debt Ceiling AgreementFollow us on Twitter:Alex Rifaat: @alexrifaatDavid 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 Analysts’ chief economist Martin Sullivan provides an overview of the state of the economy and how the recent debt limit bill could affect it. For additional coverage, read these articles in Tax Notes:House Sends Debt Limit Bill, IRS Cuts to SenateDid the Pandemic Help or Hurt the Economy?Follow us on Twitter:Marty Sullivan: @M_SullivanTaxDavid Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Former IRS Commissioner David Kautter, now with RSM, discusses the recently released report on the feasibility of an IRS-run direct file program. For additional coverage, read these articles in Tax Notes:Free Direct-File Pilot Will Launch Next Year, IRS SaysReport of Free File Prototype Irks Top Senate Finance RepublicanUse of Free File Service Dropped This Filing Season, TIGTA FindsWill Free File Alliance Survive Competition From the IRS?Follow us on Twitter:Jonathan Curry: @jtcurry005David 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 reporter Andrea Muse provides an update on the state and federal lawsuits challenging Maryland’s digital advertising tax. Listen to our previous episodes on this:The Fight Over Maryland’s Digital Advertising Tax, Part 1The Fight Over Maryland’s Digital Advertising Tax, Part 2For additional coverage, read these articles in Tax Notes:Maryland High Court Hands State Victory in Digital Ad Tax SuitMaryland High Court Focuses on Exhaustion of Remedies in Digital Ad Tax SuitMaryland Urges State High Court to Uphold Digital Ad TaxComcast, Verizon Respond to Professors in Maryland Digital Ad Tax SuitDigital Ad Tax Unconstitutional, Companies Tell Maryland Supreme CourtFourth Circuit Urged to Allow Federal Digital Ad Tax Suit to ProceedMaryland Urges Fourth Circuit to Reject Digital Ad Tax SuitFollow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Professors Bridget Crawford and Victoria Haneman discuss the estate and gift tax and how it could apply to the gifts received by Supreme Court Justice Clarence Thomas. For additional coverage, read these articles in Tax Notes:Harlan Crow Dodges Wyden Request for Details on Thomas GiftsWyden May Pursue Harlan Crow’s Tax RecordsWyden Asks Harlan Crow for Details of Gifts to ThomasIn our “Editors’ Corner” segment, Ellen Aprill, the John E. Anderson Professor of Tax Law Emerita at Loyola Marymount University’s Loyola Law School, chats about her Tax Notes piece, “Reviewing For-Profit Philanthropy and the 1969 Tax Reform 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

Tax Notes reporter Andrew Velarde discusses the penalty dispute in Farhy v. Commissioner and the case’s implications for other penalties and future refund decisions. For additional coverage, read these articles in Tax Notes:In Farhy’s Wake, Taxpayer Advocate Renews Call for Penalty ChangeFallout From Farhy on Assessable Penalties Could Be ExtensiveIRS Lacks Assessment Authority for Information Return PenaltiesInformation Return Penalty Assessment Controversy Still SwirlsInformation Return Penalty Assessment Fight Coming to a HeadFollow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Professor Kathleen Claussen of Georgetown Law discusses how the proposed regs for the new clean vehicle tax credit affect the EU and other countries without a free trade agreement. For additional coverage, read these articles in Tax Notes:Volkswagen EV Gains Tax Credit EligibilityTreasury Balancing Act on EV Tax Credits Leaves Open QuestionsTaxwriters Criticize Trade Rep on EV Tax Credit TransparencyEU and U.S. Draw Closer to Energy Tax Credit DealEU Steps Up Its Efforts to Match U.S. Inflation Reduction ActFollow us on Twitter:Sarah Paez: @PaezWritesDavid Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Professor Samuel Brunson of Loyola University Chicago discusses social media tax scams highlighted in the IRS’s 2023 “Dirty Dozen” list of scams and how to spot this misinformation. For more, read "Be Wary of Tax Advice on Social Media, IRS Warns," in Tax Notes.In our “Editors’ Corner” segment, Robert van Brederode, the founding partner of BrederodeTax LLC, chats about his Tax Notes piece, “Disclosure of Presidential Tax Returns Violates Right to Privacy.” Follow us on Twitter:Cady Stanton: @cady_stantonDavid Stewart: @TaxStewTax Notes: @TaxNotes**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

Former IRS Commissioner Fred Goldberg, now with Skadden, shares his thoughts on the IRS’s strategies and proposals outlined in the recently released spending plan for the $80 billion granted by the Inflation Reduction Act. For additional coverage, read these articles in Tax Notes:Werfel to Address IRS Budget and Filing Season at Senate HearingScholar Suggests Reforming IRS Over Spending More on EnforcementForeign Taxpayers Cautiously Optimistic About IRS’s Payment PlanEverybody Wins Under IRS’s New Compliance Model, Observers SayLong-Awaited IRS Spending Plan Still Lacks Key DetailsIRS Spending Plan Puts Emphasis on Centralizing ActivitiesAnalysis: Transforming How the IRS Serves TaxpayersFollow us on Twitter:Jonathan Curry: @jtcurry005David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxplanning23.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.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Tax Notes contributing editor Robert Goulder discusses the history of bank secrecy, Credit Suisse’s role in it, and the bank’s recent collapse. For additional coverage, read these articles in Tax Notes:Government Goes After ‘Bank Hopping’ Couple for FBAR PenaltiesFinance Committee Says Hidden Swiss Bank Accounts Fight Isn't OverUBS May Have Bought Credit Suisse’s Undeclared Account TroublesFATCA Shortfalls Bring Calls for Elimination, Better EnforcementFrance Again Denies UBS Whistleblower’s Compensation RequestReport: U.K. Residents Have £570 Billion Stashed in Tax HavensFollow us on Twitter:Robert Goulder: @RobertGoulderDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxplanning23.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.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Tax Notes legal reporter Caitlin Mullaney discusses ChatGPT’s understanding of tax. For more, read "Off the Beaten Tax: Could the Robots Be Coming for the Tax Preparers?" in Tax Notes.Follow us on Twitter:Caitlin Mullaney: @MullaneyWritesDavid 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

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

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, “Transfer Pricing's Next Generation.”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

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 2023Leaderless IRS Threatens Credibility Crisis in Key Months AheadRepublicans Voice Concerns to GAO on IRS Funding OversightFormer Officials: Success of IRS Funding Boost Is at ‘Serious Risk’Ex-IRS Official Predicts Rapid Benefits From IT UpgradesSenate GOP Frets Over ‘Largely Unbridled’ IRS FundingFollow us on Twitter:Jonathan Curry: @jtcurry005David 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

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 RulingMedtronic II’s Unspecified Method Raises Specific QuestionsTax Court Should Never Have Heard Whistleblower Case, IRS SaysTax Court’s Sealed Case Iceberg Will Soon Be Fully ThawedIn our “Editors’ Corner” segment, Filippo Noseda, a partner at Mishcon de Reya LLP and a visiting professor at King’s College in London, chats about his Tax Notes series on potentially corrupt behavior with FATCA and EU public registers.   Follow us on Twitter:David 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

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: @zgulnarPaige Jones: @paigeleejonesJordan Parrish: @JoParrish96David 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

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 SaysKwarteng Forced Into ‘Screeching U-Turn’ on Income Tax RatesKwarteng to Bring Forward Medium-Term Fiscal PlanKwarteng Criticized Over Delayed Publication of OBR ForecastU.K. Treasury Stands Firm Amid Criticism of Tax Measures In our “Editors’ Corner” segment, Karl Frieden, vice president and general counsel of the Council On State Taxation, chats about his coauthored Tax Notes piece, “Down the Rabbit Hole: Sales Taxation of Digital Business Inputs.” We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.Follow us on Twitter:David 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

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 TaxFor additional coverage, read these articles in Tax Notes:IRS Officials Turn Attention and Increased Resources to IRA Lawmakers Indefinite on SPAC Buyback Tax ReliefNew Trouble Ahead for SPACs: The Stock Buyback TaxBuyback Tax May Alter Equity Compensation and Retirement PlansWe want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.Follow us on Twitter:Chandra Wallace: @ChandraSWallaceDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by SafeSend. For more information, visit safesend.com.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 Ryan Finley discusses the latest updates in recent transfer pricing cases Eaton and Medtronic II. Listen to related episodes:Transfer Pricing Litigation UpdateCoca-Cola Transfer Pricing Challenge FizzlesFor additional coverage, read these articles in Tax Notes:Analysis: Medtronic and the Role of Unspecified Transfer Pricing MethodsMedtronic Might Trigger Up to $2 Billion Tax LiabilitySixth Circuit Sides With Eaton in APA Cancellation AppealMedtronic II’s Unspecified Method Raises Specific QuestionsIn our “Editors’ Corner” segment, Fernanda Kotzias, a counselor at the Brazilian Administrative Tax and Customs Court of Appeal, chats about her coauthored Tax Notes piece, “Brazil-U.S. Trade Agreement: A New Chapter for Trade Facilitation.” We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.Follow us on Twitter:Ryan Finley: @ryanmfinleyDavid 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

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 TaxFor additional coverage, read these articles in Tax Notes:U.S. Is Lagging on Social Cost of Carbon, Study SaysLawmakers Seek Assistance for Clean Energy and EV Tax CreditsYellen to Promote New Tax Measures With Speaking TourFollow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Avalara. For more information, visit avalara.com/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

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 StrategyIRS Urged to Budget for TransparencyYellen to Promote New Tax Measures With Speaking TourTax Professionals See Little to Fear in IRS Hiring BlitzCBO: IRS Funding Won’t Generate Much From Taxpayers Under $400KIn our “Editors’ Corner” segment, Sarah-Jane Morin, a partner with Morgan, Lewis & Bockius LLP, chats about her coauthored Tax Notes piece, “How the Definition of Digital Asset Brokers Was Brokered.” We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.Follow us on Twitter:Jonathan Curry: @jtcurry005David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Avalara. For more information, visit avalara.com/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

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: @MullaneyWritesDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Avalara. For more information, visit avalara.com/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

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 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:Nana Ama Sarfo: @nanaama_sarfoDavid 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

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 ConcernsHard Part Begins for IRS and Treasury as Biden Signs Reconciliation BillCritics Recall BURP in Debate Over Corporate Minimum TaxWe want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.Follow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Avalara. For more information, visit avalara.com/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

Kyle Pomerleau of the American Enterprise Institute discusses the key tax provisions of the Inflation Reduction Act and what they mean for the future of tax policy. For additional coverage, read these articles in Tax Notes:House Democrats Tee Up Tax Bill Debate and Nix GOP AmendmentsCritics Recall BURP in Debate Over Corporate Minimum Tax Democrats Play Whack-a-Mole as GOP Rages Against IRS Funding Partnership Rules Likely at Root of Corporate Minimum Tax FightBiden and Democrats Relish Passage of Reconciliation BillWe want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.Follow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by SafeSend. For more information, visit safesend.com.For more information and to download the Tax Advisory Industry Report, visit taxnotes.co/report.For more information about the Tax Analysts Public Service Fellowship, visit our press release at taxnotes.com/fellowship.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Tax Notes reporter Benjamin Guggenheim discusses the latest tax legislation on Capitol Hill: the recently passed CHIPS and Science Act and the revived reconciliation bill known as the Inflation Reduction Act. For additional coverage, read these articles in Tax Notes:Sinema Wants Carried Interest Out of Reconciliation, Reports SayClawbacks Will Prevent Companies From Exporting CHIPS BenefitsEx-Treasury Secretaries Support Inflation Reduction ActDemocrats Hit Back at Criticism of Inflation Reduction ActReconciliation Tax Reform Limited by Delicate NegotiationsComputer Chip Bill Passes House, Heads for Biden SignatureKey Senators Reach Deal on Corporate Tax, Carried InterestIn our “Editors’ Corner” segment, John Craig, an associate in the Washington office of Gibson, Dunn & Crutcher LLP, chats about his coauthored Tax Notes piece, “The Appeals Access Saga Continues.” We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.Follow us on Twitter:Benjamin Guggenheim: @ben_guggenheimDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by SafeSend. For more information, visit safesend.com.For more information about the Tax Analysts Public Service Fellowship, visit our press release at taxnotes.com/fellowship.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Martin A. Sullivan, Tax Analysts’ chief economist, revisits the United States’ economic path to inflation and discusses mitigation efforts for a possible recession. For more inflation coverage on the podcast, listen to Inflation, Tax, and the COVID-19 Economy.For additional coverage, read these articles in Tax Notes:Grassley Follows Up With Second Inflation-Indexing PackageNorth Carolina Republicans' Budget Preserves Income Tax CutsCalifornia Budget Deal Includes Billions in Inflation ReliefWe want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.Follow us on Twitter:Martin Sullivan: @M_SullivanTaxDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by SafeSend. For more information, visit safesend.com.For more information and to download the Tax Advisory Industry Report, visit taxnotes.co/report.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Tax Notes chief correspondent Stephanie Soong Johnston recaps the agreement on the OECD’s two-pillar corporate tax reform plan and discusses recent roadblocks to full implementation.Listen to more podcast episodes on the OECD's tax reform plan:The End Is Nigh: An Update on the OECD Tax Reform PlanThe Beginning of the End? An Update on the OECD Tax Reform PlanNew Year, New Tax Rules? An OECD Tax Reform Project UpdateFor additional coverage, read these articles in Tax Notes:U.K. Moves to Implement OECD-Brokered Global Minimum Tax RulesG-20 Ministers Push Ahead on Global Tax Reform Amid U.S. HurdlesWhite House Downplays Global Tax Deal ConcernsIndia Calls for Syncing Pillar 2 Treaty Rule and Amount B RulesOECD Fills in More Blanks on Amount A Draft Model Tax RulesTreasury to Nix Tax Treaty With Hungary for EU Minimum Tax VetoSupport Rises for Circumventing Hungary on Pillar 2Hungarian Lawmakers Nix EU Pillar 2 Minimum Tax DirectiveIn our “In the Pages” segment, Heydon Wardell-Burrus, a researcher at the Oxford Centre for Business Taxation, chats about his Tax Notes piece, “Can Pillar 2 Be Leveraged to Save Pillar 1?”We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.Follow us on Twitter:Stephanie Soong Johnston: @SoongJohnstonDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by SafeSend. For more information, visit safesend.com.For more information about the Tax Analysts Public Service Fellowship, visit our press release at taxnotes.com/fellowship.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Tax Notes reporter Jonathan Curry discusses the IRS audits of former FBI Director James Comey and his deputy, Andrew McCabe, and why they’ve drawn attention from the tax community. For additional coverage, read these articles in Tax Notes:House and Senate Taxwriters to Quiz Rettig in Private MeetingsRettig Requests TIGTA Investigation of Comey, McCabe AuditsFormer IRS Officials Skeptical of Foul Play in Comey, McCabe AuditsWe want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.Follow us on Twitter:Jonathan Curry: @jtcurry005David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by SafeSend. For more information, visit safesend.com.For more information and to download the Tax Advisory Industry Report, visit taxnotes.co/report.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Nicholas Mowbray of BakerHostetler discusses the recently enacted Superfund excise taxes on chemicals and hazardous substances and some compliance concerns and uncertainty surrounding them.  For additional coverage, read these articles in Tax Notes:IRS Releases New Environmental Taxes Form as Superfund Kicks InIRS Issues Rules on Requesting Superfund Substance List ChangesIRS Releases Rates for Superfund Chemical Excise TaxIRS Issues Lengthy List of Substances to Face Superfund TaxIn our “In the Pages” segment, Nikki Dobay, a partner with Eversheds Sutherland (US), chats about her Tax Notes piece, “Cross-Border State Legislative Tax Wars: Is This Just the Beginning?” We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.Follow us on Twitter:Nana Ama Sarfo: @nanaama_sarfoDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by SafeSend. For more information, visit safesend.com.For more information about the Tax Analysts Public Service Fellowship, visit our press release at taxnotes.com/fellowship.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

La Posada Tax Clinic Director Robert Wunderle discusses the importance of low-income taxpayer clinics to the tax system and how his clinic serves the Twin Falls, Idaho, community. For more information about the Tax Analysts Public Service Fellowship, visit taxnotes.com/fellowship.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

Elaine Maag of the Urban-Brookings Tax Policy Center looks at lessons learned from the 2021 advance child tax credit and its potential political future.  Listen to our other episodes on the child tax credit:The Advance Child Tax Credit: Changes Coming?The Advance Child Tax Credit: What Lies AheadFor additional coverage, read these articles in Tax Notes:Analysis: Resolving the Child Tax Credit ConundrumBoosted Child Credit Helped More Parents Feel Financially SecureGAO Suggests Tax Credits Contribute to Racial and Gender DisparitiesInflation, Child Tax Credit Rollback Endanger Business Tax BreaksIn our “In the Pages” segment, Omri Marian, professor of law and academic director of the graduate tax program at the University of California, Irvine School of Law, chats about his Tax Notes piece, “Law, Policy, and the Taxation of Block Rewards.” Follow us on Twitter:Marie Sapirie: @MarieSapirieDavid Stewart: @TaxStewTax Notes: @TaxNotes**For more information about the Christopher E. Bergin Award for Excellence in Writing, visit taxnotes.com/students.This episode is sponsored by SafeSend. For more information, visit safesend.com.For more information about the Tax Analysts Public Service Fellowship, visit our press release at taxnotes.com/fellowship.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Marie-France Dompierre of Davies Ward Phillips & Vineberg discusses how Canada taxes professional athletes who aren’t Canadian residents. For more, read Dompierre's article, "An ‘Expensive’ Trade? Taxation of Nonresident Professional Athletes Playing in Canada," in Tax Notes.For more episodes on taxes and sports, listen to:The NCAA vs. Taxation: How Colleges Are Caught in the MiddleTaxing College Athletes After NCAA v. AlstonFollow us on Twitter:Stephanie Soong Johnston: @SoongJohnstonDavid Stewart: @TaxStewTax Notes: @TaxNotes**Tax Analysts is honored to be recognized by The Washington Post as a 2022 Top Workplace in the D.C. metro area. For more information, visit taxnotes.com/dc2022. This episode is sponsored by SafeSend. For more information, visit safesend.com.This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.For more information about the Christopher E. Bergin Award for Excellence in Writing, visit taxnotes.com/students.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Raymond Stahl of Ernst & Young discusses concerns about the final regulations for claiming foreign tax credits, particularly how they affect creditability, withholding, and treaty benefits. For additional coverage, read these articles in Tax Notes:Yellen Nixes Foreign Tax Credit Reg Delay, Defends OECD TalksTreasury Offers More Details on FTC Royalty Withholding CarveoutValuation Allowances Soften FTC Regs' Blow for Some TaxpayersFTC Analysis Worries Persist in Regs, USCIB Warns U.S. TreasuryTax Treaties May Offer Relief From More Troublesome FTC RegsFTC Regs’ Attribution Requirement Raises Administrability IssuesIn our “In the Pages” segment, Kathleen Wright, director of the state and local tax program in the School of Taxation at Golden Gate University, chats about her Tax Notes piece, “The States’ Response to Wynne Seven Years Later.” Follow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**For more information about the Christopher E. Bergin Award for Excellence in Writing, visit taxnotes.com/students.This episode is sponsored by SafeSend. For more information, visit safesend.com.This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.For more information about the Tax Analysts Public Service Fellowship, visit our press release at taxnotes.com/fellowship.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Johan Langerock, policy adviser in the European Parliament, discusses his visit to Washington, the future of the OECD two-pillar tax plan, and the EU’s green initiative. For additional coverage, read these articles in Tax Notes:DSTs ‘Back on Table’ if U.S. Doesn’t Adopt Pillar 1, MEPs SayEU Stays Focused on Pillar 2 Despite Pillar 1 DelaysPressure Mounts for EU Ministers on Pillar 2 AgreementEU Lawmakers Back Climate Plans but Challenges RemainFollow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**For more information about the Christopher E. Bergin Award for Excellence in Writing, visit taxnotes.com/students.This episode is sponsored by SafeSend. For more information, visit safesend.com.This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Tax Notes reporter Benjamin Valdez discusses the Florida legislation eliminating Disney's special tax district, what led to its passage, and what to expect in the future. For additional coverage, read these articles in Tax Notes:Federal Judge Dismisses Taxpayers' Suit Over Disney District BillFlorida Taxpayers Sue Over Disney Tax District DissolutionFlorida Governor Signs Bill to End Disney's Special Tax DistrictFlorida Bill to Eliminate Disney’s Special Tax District Goes to GovernorFlorida Governor Seeks to End Disney’s Special Tax DistrictFollow us on Twitter:Benjamin Valdez: @benmvaldezDavid Stewart: @TaxStewTax Notes: @TaxNotes**For more information about the Tax Analysts Public Service Fellowship, visit our press release at taxnotes.com/fellowship.This episode is sponsored by SafeSend. For more information, visit safesend.com.This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Tax Notes reporters Paul Jones and Nathan Richman discuss the $141 million settlement over Intuit’s TurboTax Free Edition program and the potential tax break for Intuit. For additional coverage, read these articles in Tax Notes:TurboTax Settlement May Open the Door to Huge Tax BreakIntuit, States Enter Settlement Over ‘Free File’ ScandalGAO: Taxpayer Use of Free File Waned After Intuit’s ExitIntuit’s Ad Campaign for ‘Free’ Tax Software Draws FTC IreIntuit to Exit Free File AllianceIntuit Fails to Secure Injunction in Tax Prep 'Bait-and-Switch' FightIntuit Free File Arbitration Strategy BackfiresNew York Governor Calls for Investigation of Tax Return PreparersIn our “In the Pages” segment, Allison Christians, the H. Heward Stikeman Chair in Tax Law at McGill University in Montreal, chats about her Tax Notes piece, “Let the GILTI/GLOBE Games Begin.” Follow 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 Avalara. For more information, visit avalara.com/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Elodie Lamer and Nana Ama Sarfo of Tax Notes discuss the tax implications of golden visas and passports, which allow affluent foreigners to receive residency or citizenship in exchange for a minimum level of investment. For additional coverage, read these articles in Tax Notes:EU Commission Proposes Thorough Examinations of Golden VisasEU Commission Steps Up Legal Fight Over Maltese Golden PassportsEU Commission Wants to Revoke Golden Passports of Putin AlliesEU Considers Strengthening Security Checks of Golden Visa HoldersItaly and NGOs Call for Open Wealth Registry to Target RussiansAnalysis: Tax Incentives Among the Lures Targeting Digital NomadsVanuatu’s Golden Passport Regime Endangers Agreement With EUEU Greenlights Malta's Plans for Tackling Tax AvoidanceFollow us on Twitter:Elodie Lamer: @ElodieLamerNana Ama Sarfo: @nanaama_sarfoDavid Stewart: @TaxStewTax Notes: @TaxNotes**For more information about the Tax Analysts Public Service Fellowship, visit our press release at taxnotes.com/fellowship. This episode is sponsored by SafeSend. For more information, visit safesend.com.This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Timothy Noonan of Hodgson Russ LLP discusses how some states tax remote employees and the effect of temporary pandemic tax changes. For additional coverage, read these articles in Tax Notes:Bill Seeks to Shield Teleworkers From St. Louis's Earnings TaxAnalysis: The Pandemic’s Tax Fallout ContinuesRemote Work Complicates Employer Tax Compliance, Pressures States to Revise RulesNew York Remote Work Rules Clash With COVID-19 Realities, Experts SayIn our “In the Pages” segment, Doug Borg, a manager in the Washington office of RSM US LLP, chats about his coauthored Tax Notes piece, “Puerto Rico Resident Exemption to Be Focus of IRS Audit Campaign.”Follow 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 Avalara. For more information, visit avalara.com/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Beth Viola and Nicole Elliott of Holland & Knight discuss the latest clean energy tax proposals and the likelihood of their passage in Congress. For additional coverage, read these articles in Tax Notes:Bipartisan Energy Bill May Focus on Carbon Capture CreditsAnalysis: Low-Carbon Hydrogen Credits Break ThroughGreen Tax Credits Spotlighted in State of the UnionFollow us on Twitter:Marie Sapirie: @mariesapirieDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by SafeSend. For more information, visit safesend.com.This episode is sponsored by the District of Columbia Bar. For more information, visit dcbar.org.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Valeria Tarasenko of Dentons Kyiv discusses the Ukrainian government’s tax policy changes in response to the Russian invasion. For additional coverage, read these articles in Tax Notes:Ukraine Issues Guidance on Corporate Tax BenefitsArgentina Proposes Tax on Profits of Firms Benefiting From WarICRICT Calls on G-20 to Establish Global Asset RegistryNGOs Highlight Effectiveness of Taxing Russian EnergyBipartisan Bill Targets Foreign Tax Credits in RussiaUkraine Considering Tax Increases for MNEs With Ties to RussiaOECD Expects More Information Requests as War in Ukraine RagesIn our “In the Pages” segment, Robert van Brederode, the founding partner of BrederodeTax LLC, chats about his Tax Notes International article, “Ethical Equilibrium in Taxation.” Follow us on Twitter:Sarah Paez: @PaezWritesDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by SafeSend. For more information, visit safesend.com.This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.This episode is sponsored by the District of Columbia Bar. For more information, visit dcbar.org.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

IRS Commissioner Charles Rettig discusses the current state of the tax agency, including the paper return backlog, technology improvements, and hiring updates. Listen to the entire interview here: The State of the IRS with Commissioner Charles RettigFor additional  coverage, read these articles in Tax Notes:Rettig Warns Against New Info Reporting Rules Without FundingNew Tax Credits Blamed for Huge Number of 2021 Filing ErrorsNew Hiring Authority Paying Off for IRS, Rettig SaysTaxpayer Advocate Urges Rapid IRS Uptake of Paper-Scanning TechIRS Modernization Has Means but Not Funding, Rettig SaysRettig Makes a Big Backlog Pledge, Defends Audit PrioritiesFollow us on Twitter:Cara Griffith: @TaxCaraGriffithDavid Stewart: @TaxStewTax Notes: @TaxNotesFor more about the Christopher E. Bergin Award for Excellence in Writing, visit taxnotes.com/students.**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by SafeSend. For more information, visit safesend.com.This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.This episode is sponsored by the District of Columbia Bar. For more information, visit dcbar.org.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Rohit Kumar of PwC discusses the Biden administration’s fiscal 2023 budget, explaining the new proposals and how the budget is different than the Build Back Better Act.For additional  coverage, read these articles in Tax Notes:Tax Pros Eye Biden’s Estate Tax Plans, Shrug Off Billionaire’s Tax White House Seeks Double-Digit Increase in IRS FundingPlans for Taxing the Wealthy and Corporations Grow LargerTreasury Green Book Reveals Major Changes in Tax Goals In our “In the Pages” segment, Tony Santiago, the founder and president of TaxSearch Inc., chats about his series on the hiring and retention of U.S. tax professionals. Read the first article in his series, “Tax Hiring Outlook 2022.” Follow us on Twitter:Jonathan Curry: @jtcurry005David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by SafeSend. For more information, visit safesend.com.This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.This episode is sponsored by the District of Columbia Bar. For more information, visit dcbar.org.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Tax Notes reporters Jonathan Curry and Caitlin Mullaney set the record straight on 10 common tax myths. For more coverage, read Mullaney's article in Tax Notes, "#TaxTok Answers the Request for Easy-to-Understand Tax Info."Follow us on Twitter:Jonathan Curry: @jtcurry005Caitlin Mullaney: @MullaneyWritesDavid Stewart: @TaxStewTax Notes: @TaxNotesFor more about the Christopher E. Bergin Award for Excellence in Writing, visit taxnotes.com/students.**This episode is sponsored by SafeSend. For more information, visit safesend.com.This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Marlene Nembhard Parker and Fabrizia Lapecorella discuss their partnership as the first co-chairs of the OECD inclusive framework on base erosion and profit shifting and speculate on the future of women leading international tax. For additional  coverage, read these articles in Tax Notes:  OECD's BEPS Inclusive Framework Appoints New Co-ChairOECD Tax Standard-Setting Body Appoints New ChairFollow us on Twitter:Stephanie Soong Johnston: @SoongJohnstonDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the the American Bar Association Tax Section. For more information, visit ambar.org/taxnotes.This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Tax Notes reporter Andrew Velarde discusses the tax structure dispute in Whirlpool v. Commissioner and the case’s future implications for multinational companies. For additional  coverage, read these articles in Tax Notes: No Full Court Rehearing for Whirlpool, Sixth Circuit SaysWhirlpool Agitated Over Attempt to Brand It a Tax CheatParts Manufacturer Sees Daylight Between Itself and WhirlpoolDOJ Urges Circuit to Reject Whirlpool’s Call for RehearingGroups Line Up to Warn Circuit About Whirlpool FalloutWhirlpool Wants Circuit to Give Branch Income Case Another SpinWhirlpool’s Circuit Court Loss Could Cost It $95 MillionIn our “In the Pages” segment, Gary Wilcox, a partner at Mayer Brown LLP, chats about his coauthored Tax Notes piece, “Will Jurisdictional Nexus Survive Chevron Step 1?”Follow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the the American Bar Association Tax Section. For more information, visit ambar.org/taxnotes.This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan Parrish

Professor Richard Schmalbeck of Duke University Law School discusses college sports and taxation, including the potential effect of compensation for coaches and athletes on colleges’ tax-exempt status. For more, read Schmalbeck and Zelenak's paper, "The NCAA and the IRS: Life at the Intersection of College Sports and the Federal Income Tax."For related coverage, read these articles in Tax Notes: Taxwriter Questions More Universities About Coaches' SalariesTaxwriter Questions Big Salaries of Two College CoachesListen to the episode mentioned: Taxing College Athletes After NCAA v. AlstonFollow us on Twitter:Robert Goulder: @RobertGoulderDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the the American Bar Association Tax Section. For more information, visit ambar.org/taxnotes.This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan Parrish

Martin A. Sullivan, Tax Analysts’ chief economist, provides an overview of the U.S. economy before and during the COVID-19 pandemic, explaining the drastic increase in inflation and what is needed to curb it. For more, read Sullivan's article in Tax Notes, "Your Quick Guide to the COVID-19 Economy and the Future of Inflation."Listen to the episodes mentioned in this interview:Breaking Down the American Rescue Plan ActCountering the Coming Coronavirus RecessionFollow us on Twitter:Martin Sullivan: @M_SullivanTaxDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the the American Bar Association Tax Section. For more information, visit ambar.org/taxnotes.This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan Parrish

Professor Adam Crepelle of the George Mason University Antonin Scalia Law School discusses the complicated tax relationship between U.S. states and Native American tribes.Listen to more Tax Notes Talk episodes from our critical tax theory series:Wealth, 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 PolicyIn our “In the Pages” segment, Tatiana Falcão, an international tax law consultant and policy adviser, chats about her Tax Notes series on cryptocurrency. Follow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the the American Bar Association Tax Section. For more information, visit ambar.org/taxnotes.This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan Parrish

Pascal Saint-Amans discusses his decadelong tenure as the director of the OECD Centre for Tax Policy and Administration and what’s to come in the future. For additional coverage, read these articles in Tax Notes: A Decade of Change: OECD Tax Chief Looks Back at 10 Years on the JobOECD Working to Cut Revenue Sourcing Complexity, Tax Chief SaysUncoordinated Climate Policies Risk Carbon Leakage, OECD WarnsCountries Must Unite on Carbon Pricing, OECD Tax Chief SaysConversations: Pascal Saint-AmansFollow us on Twitter:Stephanie Soong Johnston: @SoongJohnstonDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the the American Bar Association Tax Section. For more information, visit ambar.org/taxnotes.This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan Parrish

Eelco van der Enden, the new CEO of the Global Reporting Initiative, discusses the growing environmental, social, and governance landscape and why tax is a necessary and important part of ESG reporting. For more, read Sarfo's article on van der Enden, "New GRI CEO Shares Vision on ESG Tax Disclosures."In our “In the Pages” segment, Steven Wlodychak, the former indirect state and local tax policy leader for EY, chats about his upcoming Tax Notes piece, “State PTE Tax Updates: Agency Guidance and Even More Differences!” Follow us on Twitter:Nana Ama Sarfo: @nanaama_sarfoDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the the American Bar Association Tax Section. For more information, visit ambar.org/taxnotes.This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan Parrish

Tax Notes reporter Jonathan Curry reviews President Biden’s tax policy campaign promises after one year in office and where those proposals, including the Build Back Better Act, stand today. For additional coverage, read these articles in Tax Notes: Build Back Better Talks Reset, Without a Deadline This TimeManchin Calls Build Back Better ‘Dead’; Schumer Vows to AdvanceHouse and Senate Reconciliation Bills Differ on 24 Tax ProvisionsHope Springs Eternal for Some of Biden’s Tax PrioritiesOECD Global Tax Deal a Testament to Multilateralism, Yellen SaysBiden Backs Breaking Up Build Back Better ActFollow us on Twitter:Jonathan Curry: @jtcurry005David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the the American Bar Association Tax Section. For more information, visit ambar.org/taxnotes.This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan Parrish

Max Dilendorf of the Dilendorf Law Firm PLLC discusses non-fungible tokens, or NFTs, and the related tax planning and compliance issues. In our “In the Pages” segment, Edward Zelinsky, Morris and Annie Trachman Professor of Law at the Benjamin N. Cardozo School of Law of Yeshiva University, chats about his recent Tax Notes piece, “Simplifying Income Tax Reporting for Americans Abroad.” For additional coverage, read these articles in Tax Notes: More Cryptocurrency Reporting Changes May Be on the HorizonOECD Ponders Tax Implications of Non-Fungible TokensNFT Markets Create More Tax Concerns Than Just GainsState Taxes and the Digital Economy: NFTs and the MTC ProjectFollow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the UC Irvine School of Law's Graduate Tax Program. For more information, visit the-tare.com.This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.This episode is sponsored by the the American Bar Association Tax Section. For more information, visit ambar.org/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan Parrish

Beverly Winstead of the Law Office of Beverly Winstead LLC and Paul Miller of Miller & Co. LLP discuss the 2022 filing season’s challenges and considerations in the third year of the pandemic. For additional coverage, read these articles in Tax Notes: Ineligible Taxpayers May Be Able to Keep Child Tax CreditsLawmakers Report Surge in Requests for Help With Unresponsive IRSCongress May Consider Pausing Automated IRS NoticesTaxpayer Advocate Report Prompts Concern, Emergency Funds RequestTreasury and IRS Prepare for the Worst as Filing Season LoomsFollow us on Twitter:Marie Sapirie: @MarieSapirieDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the the American Bar Association Tax Section. For more information, visit ambar.org/taxnotes.This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.This episode is sponsored by the UC Irvine School of Law's Graduate Tax Program. For more information, visit the-tare.com.This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan Parrish

Will Morris, former chair of the tax committee at Business at OECD, reflects on his nearly decadelong tenure and experiences leading the business community through OECD global corporate tax reform projects. Read Soong Johnston's profile on Morris: Changing of the Guard: Ex-BIAC Tax Chair Reflects on TenureFollow us on Twitter:Stephanie Soong Johnston: @SoongJohnstonDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the UC Irvine School of Law's Graduate Tax Program. For more information, visit the-tare.com.This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.This episode is sponsored by the the American Bar Association Tax Section. For more information, visit ambar.org/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan Parrish

In honor of Tax Notes Talk’s 200th episode, we review some of our favorite interviews and discussions from the last 100 episodes.In our “In the Pages” segment, Andrew Hughes, a Brussels-based economist who specializes in transfer pricing, valuation, and risk management, chats about his Tax Notes series on transfer pricing. Listen to our 100th episode: Tax Notes Goes To Court (Again) Find out the answer to the tax trivia question by listening to The Category Is Tax Trivia.Listen to the episodes mentioned:Wealth, Inequality, and Taxes in the U.S.Talking With the National Taxpayer Advocate: A Look AheadThe End Is Nigh: An Update on the OECD Tax Reform PlanTalking With Paul Tang: Tax Fairness in the EUHow Tax Policy Can Help Low-Income Americans’ Pandemic PlightTalking With the Tax Court Chief Judge: A Year of Change50 Years Later: The Fight for Tax TransparencyThe BEPS Project: 5 Years LaterA Very Special EpisodeFrom Henry VIII to James Bond: Weird Tax Facts Throughout HistoryThe CARES Act: What's New and What's Next Follow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the the American Bar Association Tax Section. For more information, visit ambar.org/taxnotes.This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.This episode is sponsored by the UC Irvine School of Law's Graduate Tax Program. For more information, visit the-tare.com.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Christa Goad

Tax Analysts Chief Content Officer Jeremy Scott reviews the 2021 developments in U.S. tax legislation and speculates what lies ahead in 2022. For additional coverage, read these articles in Tax Notes: Schumer Vows Build Back Better Vote as Manchin, Dems SquabbleBuild Back Better Act Will Drag on Into New YearChild Credit Deadline Adds Pressure to Reconciliation EffortsUncertainty Mars Future of Advance Child Credit AdministrationRepublican Senators Eye Legislative Fix for Crypto RulesHouse Sends Infrastructure Bill to Biden, With Pledge to Do MoreFollow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the UC Irvine School of Law's Graduate Tax Program. For more information, visit the-tare.com.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: Christa Goad

Tax Notes reporters recap some of the unusual tax stories they covered in 2021, from an international basketball player’s tax troubles to a court fight in India over a Michael Jackson concert tax. Listen to the following related podcast episodes:Year-End Collection: Tax Oddities of 2020Year-End Collection: Tax Oddities of 2019Year-End Collection, Volume 2: Tax OdditiesYear-End Collection, Volume 1: Tax OdditiesFor additional coverage, read these news articles in Tax Notes: Texas Senator: Curb Sports Team Incentives Over Mavericks' Anthem DustupEx-NBA Player Hit With Tax, Wire Fraud Charges for Chinese PlayFrench Tax Authorities Can Use Social Media Data to Catch FraudBeat It! Tax Waived on 1996 Michael Jackson Concert in MumbaiFollow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotesRobert Goulder: @RobertGoulderSarah Paez: @PaezWrites**This episode is sponsored by the UC Irvine School of Law's Graduate Tax Program. For more information, visit the-tare.com.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: Christa Goad

Benjamin Alarie with Blue J Legal discusses how technology is influencing and changing the tax field and the future of tax jobs.For the related episode mentioned in the intro, listen to Teaching Tomorrow’s Tax Pros.For additional coverage, read these articles in Tax Notes: Business of Tax: AI Brings Uncertainty and Opportunity to Tax PracticeBusiness of Tax: The Emergence of the High-Tech AccountantBusiness of Tax: Why Aren’t Accounting Firms Hiring Accountants?Follow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the UC Irvine School of Law's Graduate Tax Program. For more information, visit the-tare.com.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: Christa Goad

Adam Feinberg with Miller & Chevalier discusses air travel taxation, how it affects passengers, and the biggest issues for airlines. In our “In the Pages” segment, Timothy Noonan, partner with Hodgson Russ, chats about his recent Tax Notes piece, "The Nuts and Bolts of New York’s 548-Day Rule, Revisited." For additional coverage, read these articles in Tax Notes:Wisconsin Justices Affirm Denial of Property Tax Break for AirlinesGeorgia Moves to End Jet Fuel Tax Break After Delta Slams Voter LawFor a related episode, listen to Aviation Taxes: Ready For Takeoff.Follow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.This episode is sponsored by SafeSend. For more information, visit safesend.com.This episode is sponsored by the UC Irvine School of Law's Graduate Tax Program. For more information, visit the-tare.com.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Christa Goad

Carl Davis of the Institute on Taxation and Economic Policy discusses the biggest trends in state tax policy this year and those likely next year, including the implications of the Build Back Better Act. For additional coverage, read these articles in Tax Notes:Arkansas Taxwriters Float Plan to Cut Income TaxesMaryland AG: Digital Ad Tax Is Not a Penalty for TIA PurposesNew Mexico Governor Proposes Sales Tax CutGeorgia House Panel Advances IRC Conformity Bill Texas, Washington Voters Weigh In on Tax PolicyOhio Pot Legalization, Taxation Effort Can Gather SignaturesExisting Tax Rules May Already Serve Pot Tax TransitionFor related episodes, listen to:The Fight Over Maryland’s Digital Advertising Tax, Part 1The Fight Over Maryland’s Digital Advertising Tax, Part 2The State Fight to Eliminate the Federal Restriction on Tax CutsFollow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.This episode is sponsored by SafeSend. For more information, visit safesend.com.This episode is sponsored by the UC Irvine School of Law's Graduate Tax Program. For more information, visit the-tare.com.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Christa Goad

Mike Kowis, author of American Tax Trivia: The Ultimate Quiz on U.S. Taxation, challenges the Tax Notes Talk team to a game of tax trivia and discusses his new book. In a special “In the Pages” segment, Tax Notes International columnist Peter Mason chats about his new book, Building Better Taxes. Listen to related episodes:Stranger Than Fiction: Lessons From Odd Tax Facts of YoreFrom Henry VIII to James Bond: Weird Tax Facts Throughout HistoryFollow us on Twitter:Robert Goulder: @RobertGoulderStephanie Soong Johnston: @SoongJohnstonDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by SafeSend. For more information, visit safesend.com.This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Christa Goad

In the second of a two-episode series, Professor Richard D. Pomp of the University of Connecticut School of Law discusses his views on the federal lawsuit challenging Maryland’s digital advertising tax. Listen to the first episode in the series: The Fight Over Maryland’s Digital Advertising Tax, Part 1For additional coverage, read these articles in Tax Notes:Practitioner Slams Maryland’s New Digital Advertising TaxMaryland AG Argues for Dismissal of Verizon, Comcast Digital Ad Tax SuitFederal Judge Recuses Herself From Maryland Digital Ad Tax CaseMaryland Digital Ad Tax Plaintiffs Won't Reveal Some MembersTIA Not a Barrier to Maryland Digital Ad Tax Suit, Plaintiffs Argue Tax Law Professors Aid Maryland in Digital Ad Tax SuitMaryland Digital Ad Tax Suit Not Ripe, AG ArguesFollow us on Twitter:Lauren Loricchio: @LaurenLoricchioDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by SafeSend. For more information, visit safesend.com.This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Christa Goad

In the first of a two-episode series, Professor Young Ran (Christine) Kim of the University of Utah College of Law discusses her views on the federal lawsuit challenging Maryland’s digital advertising tax. Listen to our last episode on the digital advertising taxes: Digital Advertising Taxes and the StatesFor additional coverage, read these articles in Tax Notes:Practitioner Slams Maryland’s New Digital Advertising TaxMaryland AG Argues for Dismissal of Verizon, Comcast Digital Ad Tax SuitFederal Judge Recuses Herself From Maryland Digital Ad Tax CaseMaryland Digital Ad Tax Plaintiffs Won't Reveal Some MembersTIA Not a Barrier to Maryland Digital Ad Tax Suit, Plaintiffs Argue Tax Law Professors Aid Maryland in Digital Ad Tax SuitMaryland Digital Ad Tax Suit Not Ripe, AG ArguesFollow us on Twitter:Lauren Loricchio: @LaurenLoricchioDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by SafeSend. For more information, visit safesend.com.This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Christa Goad

Professor Goldburn P. Maynard Jr. of the Indiana University Kelley School of Business discusses the U.S. tax code’s effect on wealth inequality and how race has shaped the distribution of wealth. Listen to more Tax Notes Talk episodes from our critical tax theory series: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:Joe Thorndike: @JThorndikeDavid Stewart: @TaxStewTax Notes: @TaxNotesSources mentioned in the intro:Institute for Policy Studies analysisBrookings data**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by SafeSend. For more information, visit safesend.com.This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Christa Goad

National Taxpayer Advocate Erin Collins discusses the effect of the COVID-19 pandemic on taxpayers, recent IRS program changes, and what’s to come from the annual Taxpayer Advocate Service report to Congress. In our “In the Pages” segment, David Hasen, a professor at the University of Florida Levin College of Law, chats about his recent Tax Notes piece, "Three Cheers for Proposed Changes to Partnership Debt Basis Allocation Rules." For additional coverage, read these articles in Tax Notes:Private Tax Collection Shake-Up as One Contractor Replaces TwoHouse Panel Approves IRS Budget Boost as Rettig Seeks MoreMillions Anxious for IRS Guidance on Unemployment, Advocate SaysWyden Bill ‘Imminent’ to End Private Garnishment of Stimulus PayCaseload Fluctuations Concern National Taxpayer AdvocateIRS Funding Tops Taxpayer Advocate’s Legislative RecommendationsFollow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by SafeSend. For more information, visit safesend.com.This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.We are excited to announce the new Tax Notes Transfer Pricing Center! For more information, visit taxnotes.com/transferpricing.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Christa Goad

Professor Jacob Goldin of Stanford Law School discusses proposed changes to the advance child tax credit in draft legislation recently released by House Democrats. Listen to our last episode on the advance child tax credit: The Advance Child Tax Credit: What Lies Ahead For additional coverage, read these articles in Tax Notes:Child Tax Credit Targeted as Dems Clip Budget BillBiden Would Consider Lower Child Credit Income PhaseoutExpats Protest Exclusion From Expanded Child Tax CreditOlson: Getting Child Tax Credits to Families Must Be IRS PriorityColorado Governor Launches Campaign to Ease Access to Child Tax CreditSen. Brown Pledges Permanent Child Credit ExpansionAll’s Fair in Getting Child Credits Paid, Advocate ArguesFollow us on Twitter:Marie Sapirie: @MarieSapirieDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by SafeSend. For more information, visit safesend.com.This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.We are excited to announce the new Tax Notes Transfer Pricing Center! For more information, visit taxnotes.com/transferpricing.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Christa Goad

Tax Notes chief correspondent Stephanie Soong Johnston recaps the final agreement on the OECD’s two-pillar corporate tax reform plan approved in October by 136 countries of the inclusive framework. Listen to more podcast episodes on the OECD's tax reform plan:The Beginning of the End? An Update on the OECD Tax Reform PlanNew Year, New Tax Rules? An OECD Tax Reform Project UpdateDelays Ahead: An Update on the OECD’s Global Corporate Tax ReformA New Tax World Order: Coming Soon?For additional coverage, read these articles in Tax Notes:G-20 Finance Chiefs Approve OECD Global Tax Reform DealEU Should Consider Nondiscriminatory Implementation of Pillar 2Treasury Closing In on Digital Tax Repeal Deals With CountriesEU Will Propose a Pillar 2 Directive by Year-EndHill Staffers Split on Pillar 1 Treaty RequirementCountries Finalize Sweeping OECD Global Tax Reform AgreementArgentina Says Global Tax Deal Is Bad for Developing NationsFollow us on Twitter:Stephanie Soong Johnston: @SoongJohnstonDavid Stewart: @TaxStewTax Notes: @TaxNotesIn our “In the Pages” segment, Lucas de Lima Carvalho, an international tax law professor at the Brazilian Institute of Tax Law, chats about his recent Tax Notes piece, "The Andean Question: Two Pillars, Two Sides?" **This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by SafeSend. For more information, visit safesend.com.This episode is sponsored by the UC Irvine School of Law’s Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote. ***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Christa Goad

Tax Notes reporter Sarah Paez discusses the EU tax haven blacklist and the potential impact of the recently released Pandora Papers. Read Sarah's article on the EU blacklist here: EU Tax Haven Blacklist Hamstrung by Politics, Critics SayFor additional coverage, read these articles in Tax Notes:MEPs Demand Action Against Tax Avoidance After Pandora PapersPandora Papers Leak Details Widespread Use of Offshore EntitiesTurkey Evades EU Tax Haven Blacklist Once AgainEU Code of Conduct Group Reviewing Scope of Blacklist CriteriaFollow us on Twitter:Sarah Paez: @PaezWritesDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by SafeSend. For more information, visit safesend.com.We are excited to announce the new Tax Notes Transfer Pricing Center! For more information, visit taxnotes.com/transferpricing.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Christa Goad

Tax Notes Capitol Hill reporters Doug Sword and Frederic Lee return to discuss the latest tax developments with the record-breaking infrastructure and reconciliation legislation advancing in Congress. Listen to the last Tax Notes Talk episode about Congress: Keeping Up With Congress: Fall 2021 PreviewFor additional coverage, read these articles in Tax Notes:‘We Need to Get a Number,’ Neal Says of Reconciliation StalemateNeal Continues Push for Action on Retirement IssuesDemocrats Move Off $3.5 Trillion Figure, Infrastructure LinkHouse Sets Up $3.5 Trillion Reconciliation Bill for Floor VoteBank Reporting In, Stepped-Up Out of Tax Bill Options, Neal SaysCongressional Democrats Shifting on Key Tax ItemsWyden Looks to Tighten Rules Partnerships Use to Sidestep TaxesIn our “In the Pages” segment, Lynn Gandhi, a partner with Foley & Lardner LLP, chats about her recent Tax Notes cover piece, "Zelinsky — Round 2 of the Convenience of the Employer Test." **This episode is sponsored by Avalara. For more information, visit avalara.com/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: Christa Goad

Professors Bridget J. Crawford of the Pace University School of Law and Anthony C. Infanti of the University of Pittsburgh School of Law discuss viewing the U.S. tax code through a feminist lens. Listen to more Tax Notes Talk episodes from our critical tax theory series:Taxes 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 Policy**This episode is sponsored by Avalara. For more information, visit avalara.com/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: Christa Goad

Jordan Bass of the firm Taxing Cryptocurrency discusses the proposed cryptocurrency tax changes that Congress is considering, and how they could affect taxpayers and the digital asset industry.  For additional coverage, read these articles in Tax Notes:House Democrats Propose Dramatic Changes to Wash Sale RulePotential Breadth of Crypto Rules Worries IndustryNews Analysis: A Scorecard for Reconciliation, Round 2Ramp Up Crypto Reporting Now, Say Tax ProsPractitioner Suggests Another Look at Crypto-Specific AmnestyThe Cryptocurrency Legislative Battle Is Far From OverNews Analysis: DeFi-ing Crypto Financial RegulationIn our “In the Pages” segment, Rob Warren, assistant professor of accounting at the Radford University Davis College of Business and Economics, chats about his recent Tax Notes piece, "More Tax Cops Are Needed to Close the Tax Gap." **This episode is sponsored by Avalara. For more information, visit avalara.com/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: Christa Goad

Mark Strimber of RSM US LLP provides an overview of the global minimum tax rule featured in the OECD/G-20’s two-pillar project and discusses the effect it could have on various tax regimes.Listen to the episode with Tax Notes chief correspondent Stephanie Soong Johnston here: The Beginning of the End? An Update on the OECD Tax Reform PlanFor additional coverage, read these articles in Tax Notes:U.S. Must Be Bold in Global Minimum Tax Effort, Treasury SaysYellen Touts OECD Tax Deal Amid U.S. Global TCJA Reform PushTogo Joins OECD Inclusive Framework and Global Tax Reform DealOECD Tax Reform Plan Makes Sense for Ireland and EU, Macron SaysGerman-Speaking Finance Ministers Commit to OECD ProgressHungary Does Not Believe in Global Minimum Tax RateBarbados Joins OECD Corporate Tax Reform Plan**This episode is sponsored by Avalara. For more information, visit avalara.com/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: Christa Goad

Nikki Dobay, a partner with Eversheds Sutherland’s tax practice group, discusses the SALT cap workarounds for passthrough entities that many states have adopted, and possible coming developments for those policies.For additional coverage, read these articles in Tax Notes:Illinois Governor Signs Passthrough SALT Cap WorkaroundLess Expensive SALT Cap Rollbacks Still Mostly Benefit WealthyNew York Issues Guidance on SALT Cap WorkaroundSurge of SALT Workarounds Could Pose Complications for PassthroughsCalifornia Democrats Join Call to Lift SALT Deduction CapIn our “In the Pages” segment, Philip Wolf, associate at Belcher, Smolen & Van Loo LLP, chats about his new Tax Notes column, The Tax Scribe, and his first installment of the column, "Starting Strong in Tax Writing: The Opening Paragraph."**This episode is sponsored by Avalara. For more information, visit avalara.com/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: Christa Goad

Tax Notes Capitol Hill reporters Doug Sword and Frederic Lee examine the record-breaking budget and infrastructure legislation advancing on Capitol Hill and preview potential tax policy proposals coming this fall.For additional coverage, read these articles in Tax Notes:Will Dems Pay Full Freight on $3.5 Trillion Reconciliation Bill?International Tax Draft Offers New Details, but Major Gaps RemainHouse Passes Budget Bill; Flurry of Markups to FollowDemocrats Promise, GOP Fumes as $3.5 Trillion Package AdvancesInfrastructure Bill Heads to House for Potential Crypto ChangesWays and Means Dems Gaming Out How to Raise $3.5 TrillionCalifornia Democrats Join Call to Lift SALT Deduction CapMembers Hope SALT Caucus Is Short-Lived**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Christa Goad

Tax Notes legal reporter Ryan Finley discusses the latest updates in recent transfer pricing cases, including Coca-Cola and Medtronic, and reviews the upcoming Amgen case.The Coca-Cola episode can be listened to here: Coca-Cola Transfer Pricing Challenge Fizzles For additional coverage, read these articles in Tax Notes:Amgen Disputes $3.6 Billion Deficiency in Transfer Pricing CaseMedtronic Doubles Down on Its Use of CUT Method in New TrialTax Court Sides With IRS in Coca-Cola Transfer Pricing CaseCiting Comparability Questions, Eighth Circuit Vacates MedtronicCourt Finds IRS Arbitrary and Capricious in Medtronic Transfer Pricing CaseIn our “In the Pages” segment, Stephen Curtis, president of Cross Border Analytics Inc., chats about his Tax Notes piece, “Apple’s Cost-Sharing Arrangement: Frankenstein’s Monster.” ***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Christa Goad

In the second of a two-episode series, Tax Notes contributing editor Marie Sapirie interviews Shuting Pomerleau, a climate policy analyst at the Niskanen Center, about her views on a carbon tax. The first episode in the series can be listened to here: The Case Against a Carbon TaxFor additional coverage, read these articles in Tax Notes:Israel to Introduce Carbon TaxEU to Delay CBAM, ETS Own Resources ProposalsG-20 Finance Ministers Call for More Carbon Pricing CoordinationNew U.S. Position on Climate Change Doesn't Portend Carbon TaxCan a Tax Save the Planet?**This episode is sponsored by the National Society of Accountants. For more information, visit nsacct.org.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Christa Goad

In the first of a two-episode series, Tax Notes contributing editor Marie Sapirie interviews David Kreutzer, an economist at the Institute for Energy Research, about his views on a carbon tax. For additional coverage, read these articles in Tax Notes:Israel to Introduce Carbon TaxEU to Delay CBAM, ETS Own Resources ProposalsG-20 Finance Ministers Call for More Carbon Pricing CoordinationNew U.S. Position on Climate Change Doesn't Portend Carbon TaxCan a Tax Save the Planet?In our “In the Pages” segment, Walter Hellerstein, Distinguished Professor Emeritus at the University of Georgia Law School and chair of the Tax Notes State advisory board, chats about his Tax Notes piece, “Platforms: The Postscript.”**This episode is sponsored by the National Society of Accountants. For more information, visit nsacct.org.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Christa Goad

Tax Notes reporters Amanda Athanasiou and Lauren Loricchio share what they learned reporting on their recent piece, “How the Pandemic Upended Life and Work for Women in Tax,” and their personal experiences. For additional coverage, read Athanasiou's article in Tax Notes:Why Women Are Still Leaving Tax, and What to Do About It***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Christa Goad

Tax Notes chief correspondent Stephanie Soong Johnston recaps the historic agreement reached by the majority of the OECD's inclusive framework countries on its two-pillar corporate tax reform proposal. For additional coverage, read these articles in Tax Notes:OECD Tax Chief Outlines Next Steps for Global Tax Reform DealIreland to Start Consultation on Global Tax Reform Deal SoonEU Digital Levy Delay Is Welcome News, OECD Deputy Chief SaysAmount A Plan Is a Formulary Approach Test, OECD Official SaysCountries Advance Historic Global Tax Plan With New DetailsPillar 1 of Global Tax Deal on a Slower U.S. Track, Yellen SaysBrady Skeptical of Global Tax Deal Amid EU Digital Levy PushIn our “In the Pages” segment, Lewis Greenwald, managing director with Alvarez and Marsal Taxand, chats about his Tax Notes piece, “On the Exceptional Importance of Intercompany Agreements That Can Be Readily Produced.” ***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Christa Goad

Andrew Dana, a partner with Parker Poe Adams & Bernstein LLP, discusses the Supreme Court case NCAA v. Alston; name, image, and likeness rights; and how both could affect taxation of college athletes. ***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Christa Goad

Liz Armbruester, Avalara's senior vice president of global compliance, discusses the recent EU VAT e-commerce reforms and their impact on businesses and consumers worldwide.For additional coverage, read these articles in Tax Notes:EU Assures No Further Postponement of VAT E-Commerce RulesEuropean Commission Clarifies Scope of New VAT E-Commerce RulesEuropean Commission Proposes Delaying E-Commerce VAT RulesEU Fleshes Out Anti-Fraud Measures for New VAT RegimeIn our “In the Pages” segment, Margaret Ryznar, a professor at Indiana University McKinney School of Law , chats about her upcoming Tax Notes piece, “A Tax Credit for Wills.” ***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Christa Goad

Omeed Firouzi with Philadelphia Legal Assistance discusses the upcoming advance child tax credit payments and the related potential challenges for taxpayers and practitioners.For additional coverage, read these news articles and analyses in Tax Notes:What to Know About the New and Upcoming Child Tax Credit PortalsAdvance Child Credit Payment Denials Must Be Reviewed, ABA SaysIRS Planning Outreach Blitz for Nonfilers Eligible for Advance CTCPractitioners Cast Wary Eye on Periodic Advance Child CreditAdvance Child Credit Guidance and Portal Coming, IRS SaysThe Expanding Child Tax Credit and What to Watch For***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Christa Goad

Rajat Bansal, a departing member of the U.N. Committee on Experts on International Cooperation in Tax Matters, recaps the group’s milestones over the last four years and describes what challenges lie ahead.For additional coverage, read these articles in Tax Notes:The Evolution of the U.N. Tax Model — Software Payments as RoyaltiesU.N. Tax Committee Notes Support for Revising Royalty DefinitionU.N. Releases New Transfer Pricing Manual for Developing CountriesU.N. Tax Committee Greenlights Carbon Taxation HandbookU.N. Committee Approves Digital Services Tax Treaty Article TextProposed U.N. Model Treaty Article on DST on Track for 2021 ***CreditsHost: David D. StewartExecutive Producers: Jasper B. SmithShowrunner: Paige JonesAudio Engineer: Jordan ParrishGuest Relations: Christa Goad

Joseph Bishop-Henchman of the National Taxpayers Union Foundation discusses the litigation of a provision in the American Rescue Plan Act restricting states from using federal funds provided by the law to offset reductions in net tax revenue. For additional coverage, read these articles in Tax Notes:Civil Liberties Group Sides With Ohio in Offset Provision LawsuitOhio Attorney General Seeks Permanent Injunction in Tax Restriction SuitOffset Provision Guidance Could Be Thorny for States Eyeing Tax CutsJudge Denies Ohio's Request to Prevent Treasury From Enforcing Offset ProvisionJudge Dismisses Missouri's Suit Over Restriction on Federal FundingFederal Government Argues 13 States Lack Standing for Preliminary ReliefTreasury Issues Much-Awaited Guidance on Tax Offset Provision In our “In the Pages” segment, University of Virginia School of Law professor Ruth Mason chats about her recent Tax Notes piece, “State Aid Enforcement After Amazon.” ***CreditsHost: David D. StewartExecutive Producers: Jasper B. SmithShowrunner: Paige JonesAudio Engineer: Jordan ParrishGuest Relations: Christa Goad

Professor Patricia A. Cain of the Santa Clara University School of Law discusses the unique tax challenges faced by members of the LGBTQ community in the past and today. ***CreditsHost: David D. StewartExecutive Producers: Jasper B. SmithShowrunner: Paige JonesAudio Engineer: Jordan ParrishGuest Relations: Christa Goad

Kevin Brown, an associate with Morrison & Foerster LLP, discusses his proposal for taxing moon-based activity. Read Brown's piece in Tax Notes, "Tax the Moon That the Earth May Prosper: How to Tax Lunar Occupation."In our “In the Pages” segment, Steven N.J. Wlodychak, the former indirect state and local tax policy leader for EY, discusses his recent Tax Notes piece, “Why Aren’t U.S. States Subject to International Tax Treaties?” ***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Janelle JulienShowrunner: Paige JonesAudio Engineer: Jordan ParrishGuest Relations: Christa Goad

Tax Notes legal reporter Jennifer McLoughlin and contributing editor Kristen Parillo discuss two important tax cases heard by the Supreme Court: Americans for Prosperity Foundation and CIC Services.  For additional coverage, read these articles in Tax Notes:Limitations of CIC Services Opinion Are UnclearLawsuit on Access to Appeals Barred Under CIC Services, DOJ SaysSupreme Court’s CIC Services Opinion Clarifies Scope of AIAProfessor Highlights Potential Reach of California Donor Disclosure CaseCalifornia Donor Disclosure Law Is Chilling, Attorney Tells SCOTUSU.S. Lawmakers Seek Justice Barrett’s Recusal in Donor Disclosure Case**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producer: Jasper B. SmithShowrunner: Paige JonesAudio Engineer: Jordan ParrishGuest Relations: Christa Goad

Tax Notes legal reporters Ryan Finley and Kiarra M. Strocko discuss the EU General Court’s judgments in Amazon and Engie and their effect on state aid rules.  For additional coverage, read these articles in Tax Notes:Amazon May Force the EU Commission to Change Its ApproachAmazon and Engie Cast Doubt on State Aid Enforcement ApproachEngie Loses €120 Million Tax Fight Against European CommissionLuxembourg Gets Resounding Win in Amazon State Aid DecisionAmazon Must Repay €250 Million in Unpaid Taxes to Luxembourg, European Commission SaysIn our “In the Pages” segment, Alan D. Viard, a resident scholar at the American Enterprise Institute, discusses his upcoming Tax Notes piece, “Notches in the Tax System: the Good, the Bad, and the Ugly.” **This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producer: Jasper B. SmithShowrunner: Paige JonesAudio Engineer: Jordan ParrishGuest Relations: Christa Goad

Tax Notes contributing editor Robert Goulder discusses the Biden administration’s approach to the OECD’s two-pillar solution to taxing the digital economy and the potential for global consensus. For additional coverage, read Goulder's piece in Tax Notes:Treasury’s Pillar 1 Reset: In Praise of Comprehensive ScopingAll Roads Lead to Ireland: Pillar 2 and the Path of Least ResistanceThe BEPS Gambit: Will the OECD Know When to Resign?**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Janelle JulienShowrunner: Paige JonesAudio Engineer: Jordan ParrishGuest Relations: Christa Goad

 Jonathan Curry of Tax Notes recaps the tax provisions of President Biden’s American Families Plan and discusses with Dean Zerbe of Alliantgroup the finer details and its likelihood of passing Congress. For additional coverage, read these articles in Tax Notes:Yellen Leaves Door Open to Deficit-Financing Biden’s Big PlansBiden’s NII Tax Fix Destined to Be the Bane of PractitionersRepublicans Denounce Biden’s Tax Hike ProposalsLike-Kind Exchange Proposal Is a Job Killer, Say ProsDemocrats See Room for Improvement in Some Biden Tax ProposalsBiden’s Next Plan Targets Like-Kind Exchanges, Stepped-Up BasisBiden Tax Gap Plans Prompt Business, Taxpayer Rights ConcernsBiden Sets Date to Unveil Tax Proposals Aimed at the RichCharlotte Tolman of Stibbe discusses her new Tax Notes column, “In Step With Stibbe.” Check out our episode on the first package of President's Biden Build Back Better plan, "The Biden and Wyden Tax Plans."**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Janelle JulienShowrunner: Paige JonesAudio Engineer: Jordan ParrishGuest Relations: Christa Goad

Enrolled agents Eva Rosenberg and Jeffrey Schneider share their experiences on communicating with the IRS during the coronavirus pandemic and how the agency can improve.  For additional coverage, read these articles in Tax Notes:IRS Remote Employees Mull Telework Despite Processing BacklogsIRS Backlogs to Last at Least Until Summer, Taxpayer Advocate SaysFound Money and Powerlessness: Tax Pros Share 2021 Ups and DownsReturn Filing Extension Receives Widespread ApprovalIRS Data Analytics Pros Still See Need for Human TouchIRS Exec Pushes for Agency ‘Digitalization’ Funding**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Janelle JulienShowrunner: Paige JonesAudio Engineer: Jordan ParrishGuest Relations: Christa Goad

David Thompson of the National Council of Nonprofits talks about how tax policy affects tax-exempt organizations and tax issues on the nonprofit industry’s radar today.  For additional coverage, read these articles in Tax Notes:IRS Official Outlines Status of EO ExaminationsIRS Clarifies Reporting of Emergency Grants to College StudentsLawmakers Reintroduce Legislation to Expand Charitable DeductionIRS Tackling Coronavirus Guidance for EOsNonprofits Seek Enhanced Giving Deduction for Non-ItemizersBrian Hamer of the Multistate Tax Commission discusses his recent Tax Notes piece “An Insider’s View of the MTC’s P.L. 86-272 Project.” **This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Janelle JulienShowrunner: Paige JonesAudio Engineer: Jordan ParrishGuest Relations: Christa Goad

Tax Notes reporters examine President Biden’s Made in America Tax Plan and the international tax framework by Senate Finance Committee Chair Ron Wyden, D-Ore., and their international impact.  For additional coverage, read these articles in Tax Notes:Wyden Cheers New Treasury Pitch in OECD Global Tax Reform TalksBrady Lambastes Potential Tax Hikes as Invitation for InversionsTreasury Ties Corporate Reforms to Improved U.S. CompetitivenessBiden Administration’s ‘SHIELD’ Proposal Would Replace BEATSenate Dems Pitch International Tax Changes With No Set RatesYellen Stresses Global Cooperation on Minimum Corporate TaxationTax Code Plays Big Role in Biden’s Infrastructure PlansBiden Proposes Eliminating FDII, Changing Earnings-Stripping Law**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Janelle JulienShowrunner: Paige JonesAudio Engineer: Jordan ParrishGuest Relations: Christa Goad

Abdul Muheet Chowdhary of South Centre, an intergovernmental organization of developing countries, talks about how the U.N. Committee on Experts on International Cooperation in Tax Matters could be more transparent and effective for developing countries. Read his piece in Tax Notes, "Making the U.N. Tax Committee More Effective for Developing Countries."Thomas S. Neubig of the of the Council on Economic Policies talks about his recent Tax Notes piece, “Disparate Racial Impact: Tax Expenditure Reform Needed.” **This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Janelle JulienShowrunner: Paige JonesAudio Engineer: Jordan ParrishGuest Relations: Christa Goad

Joel Slemrod and Michael Keen, authors of Rebellion, Rascals, and Revenue: Tax Follies and Wisdom Through the Ages, share interesting tax facts and lessons learned from history.  Check out our related episode "From Henry VIII to James Bond: Weird Tax Facts Throughout History."**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Janelle JulienShowrunner: Paige JonesAudio Engineer: Jordan ParrishGuest Relations: Christa Goad

Benjamin Angel, director of direct taxation at the European Commission’s Directorate-General for Taxation and Customs Union, discusses the EU’s biggest tax challenges and what lies ahead.  For additional coverage, read these articles in Tax Notes:EU Digital Levy Won't Be Discriminatory, Vestager SaysEconomist Says Electricity Tax Cuts Will Help Countries Go GreenOECD Agreement Vital to Achieving Tax Fairness, EU Lawmakers SayNicholas Kuria of Conyers Dill & Pearman talks about his recent Tax Notes piece, “Tax and the British Virgin Islands: Separating Myth From Reality.” **This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Janelle JulienShowrunner: Paige JonesAudio Engineers: Jordan Parrish, Aeris StewartGuest Relations: Christa Goad

 Martin A. Sullivan of Tax Notes and Tynisa Gaines, an enrolled agent, discuss the tax provisions of the new coronavirus relief package and its impact on the economy and the tax community.  For additional coverage, read these articles in Tax Notes:Return Filing Extension Receives Widespread ApprovalHouse Approves Two-Month PPP ExtensionPreparers Eager for Guidance on Unemployment Exclusion, CreditsBiden Signs $1.9 Trillion COVID-19 Relief Bill Into LawHouse Sends Massive COVID-19 Relief Bill to BidenMoney on the Way as IRS Gears Up for Stimulus Round 3**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.This episode is sponsored by Graduate Tax Program at LMU Loyola Law School. For more information, visit lls.edu/taxnotes.  ***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Janelle JulienShowrunner: Paige JonesAudio Engineer: Jordan ParrishGuest Relations: Christa Goad

Yvette Lind, an assistant professor of tax law at the Copenhagen Business School, talks about how the coronavirus pandemic hurt gender equality and offers possible tax solutions.For additional coverage, read Lind's special report in Tax Notes: "Gender Equality, Taxation, and the COVID-19 Recovery: A Study of Sweden and Denmark." Alexandre Marcellesi of Gibson, Dunn & Crutcher discusses his upcoming article in Tax Notes on creditor continuity of interest.  **This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Janelle JulienShowrunner: Paige JonesAudio Engineer: Jordan ParrishGuest Relations: Christa Goad

Paul Tang, a Dutch member of the European Parliament, discusses the challenges facing the international tax community and his goals as chair of the subcommittee on tax.  For additional coverage, read these articles in Tax Notes:EU Must Consider Removing VAT Exemption for Financial ServicesPaul Tang Discusses The Future of EU TaxEU Parliament Tax Subcommittee to Focus on New Revenue SourcesEuropean Parliament Names Members of Permanent Tax SubcommitteeEuropean Parliament Tax Subcommittee to Formalize Leadership **This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Janelle JulienShowrunner: Paige JonesAudio Engineer: Jordan ParrishGuest Relations: Christa Goad

Rebecca Thompson of Prosperity Now, a nonprofit based in Washington, D.C., discusses how the COVID-19 pandemic has affected low-income communities and families of color in the United States, and what tax policy tools could help them. For additional coverage, read these articles in Tax Notes:IRS Plan for Monthly Child Credit Distribution Lacks DetailsIRS Has No Plans to Extend 2021 Filing Season NationwideCalls Grow for Tax Return Filing Deadline ExtensionHouse Democrats to Fight Injustices With IncentivesUniversity of Virginia professor Andrew Kahrl talks about his recent Tax Notes piece, “More for Less: How Property Taxes Fuel Racial Inequality."**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Janelle JulienShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole Wilder

Josh Goodman of the Pew Charitable Trusts talks about the organization’s recent report on how states can direct economic development to people and places in need.  **This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Janelle JulienShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole Wilder

Phyllis Jo Kubey, a solo practitioner based in New York City, and Ryan L. Losi, executive vice president at PIASCIK, discuss the 2021 tax season and the unique challenges posed by the COVID-19 pandemic. For additional coverage, read these articles in Tax Notes:Late Start to Filing Season Has More Preparers Wanting Extra TimeTax Pros Debate Later Filing Season Opening — And Closing2020 Tax Woes Likely to Haunt Practitioners Into Next YearCPAs Tackle COVID Tax Impact on AthletesCOVID-19 Shaped Tax Pros’ Business Through Filing SeasonPreparers Scramble in Pandemic Adapt-to-Survive MomentBusiness of Tax: The Strangest Filing Season in MemoryInternational tax attorney Paul J. Crispino talks about his upcoming Tax Notes piece, “Veering Off Course: Targeted Advertising and Market Taxation.” **This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Janelle JulienShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole Wilder

Morgan Scarboro of MultiState discusses the tax topics state legislatures are likely to tackle this year.For additional coverage, read these articles in Tax Notes:Experts, Activists Weigh In on Proposed Washington State Wealth TaxConnecticut Bill Looks to Prevent Double Taxation of Remote WorkersMaryland Bill Would Disallow Retroactive Tax Breaks in CARES ActKansas House Panel Proposes Marketplace Facilitator BillConnecticut Rep Proposes Digital Ad Tax on Social Media CompaniesLocal Officials Press Congress for AidMissouri Governor Calls on Lawmakers to Address Wayfair**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. SmithShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole Wilder

Tax Notes reporters Jad Chamseddine and Alexis Gravely speculate on upcoming tax changes and developments on Capitol Hill this year. Jeffrey A. Friedman of Eversheds Sutherland (US) LLP talks about his recent Tax Notes piece, “The Complexities of State Taxation of Digital Advertising.”For additional coverage, read these articles in Tax Notes:Wyden Eyes Corporate Tax, Capital Gains Reform as Finance ChairTax Staffers Highlight Focus on Bipartisanship for 117th CongressWays and Means Set to Welcome Three New GOP MembersDate Scheduled to Determine Fate of Trump’s Tax ReturnsSenate Confirms Yellen as Treasury SecretaryImmediate Tax Increases Unlikely, Treasury Official SaysRetirement and Health Benefits Seen as Likely Revenue Offsets**This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. SmithShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole Wilder

Tax Notes reporters Stephanie Soong Johnston and Ryan Finley recap the OECD’s latest public consultation on its two-pillar approach to taxing the digital economy. For additional coverage, read the article in Tax Notes:Stakeholders Push for ‘Angel List’ in OECD Minimum Tax PlanU.S. Must Rethink Stance on Global Tax Reform Deal, Harter SaysDelivering on Tax Certainty Is Critical to Pillar 1’s SuccessOECD Navigates Calls for Simplifying Global Tax Reform PlanOECD Opens Global Tax Meeting to Public for the First Time**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. Stewart Executive Producers: Jasper B. Smith, Faye McCray Showrunner: Paige Jones Audio Engineers: Derek Squires, Jordan Parrish Guest Relations: Nicole Wilder

Retired IRS economist Kim Bloomquist discusses his findings of geographic – and perhaps race and class – bias in the tax agency’s selection of audits. For additional coverage, read these articles in Tax Notes:IRS Exams Focus on EITC Claims, Not Poor, Inspector General SaysAudit Patterns Not Racially Biased, IRS Chief Tells House PanelRettig to Tax Pros: Get Clients in the Compliance ‘Zone’ Scott St. Amand of Fisher, Tousey, Leas & Ball talks about his upcoming Tax Notes piece, “Prior Supervisory Approval: The Tax Penalty Poison Pill.”**This episode is sponsored by the Tax Attorney Recruiting Event (TARE). For more information, visit the-tare.com.This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.*** CreditsHost: David D. Stewart Executive Producers: Jasper B. Smith Showrunner: Paige Jones Audio Engineers: Derek Squires, Jordan Parrish Guest Relations: Nicole Wilder

 Martin Hearson of the International Centre for Tax and Development and Emmanuel Eze of the Nigerian Federal Inland Revenue Service discuss the role and influence of developing countries in the OECD’s inclusive framework.  For additional coverage, read these articles in Tax Notes:Study Sheds Light on Inclusivity of OECD Global Tax NegotiationsLower-Income Countries Must Collaborate for Tax Policy SwayA Look Ahead: Hurry Up and Wait for a Global Tax Reform DealOECD Nails Down Date for Public Meeting on Tax Reform BlueprintsG-20 Leaders Reaffirm Commitment to Progress on Global Tax Deal**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by the Tax Attorney Recruiting Event (TARE). For more information, visit the-tare.com.This episode is sponsored by the D.C. Bar. For more information, visit dcbar.org. *** CreditsHost: David D. Stewart Executive Producers: Jasper B. Smith, Faye McCray Showrunner: Paige Jones Audio Engineers: Derek Squires, Jordan Parrish Guest Relations: Nicole Wilder

Tax Analysts Chief Content Officer Jeremy Scott reviews U.S. tax legislation passed in 2020 and speculates about what lies ahead in 2021.  For additional coverage, read the article in Tax Notes:A Look Ahead: COVID-19 Relief Likely to Be Yellen’s Legislative FocusTrump Signals He May Not Sign COVID-19 Relief BillA Look Ahead: Biden Expected to Mend Fences at WTOCongress Passes Year-End Bill With Full PPP DeductibilityProgressive Tax Aspirations Thwarted by Split CongressIn the segment “In the Pages,” Tax Notes International Editor in Chief Cathleen Phillips talks about how (and why) to write for Tax Notes.**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by the D.C. Bar. For more information, visit dcbar.org. *** CreditsHost: David D. Stewart Executive Producers: Jasper B. Smith, Faye McCray Showrunner: Paige Jones Audio Engineers: Derek Squires, Jordan Parrish Guest Relations: Nicole Wilder

Tax Notes reporters recap some of the quirkiest tax stories they encountered in 2020, from two brothers’ legal and tax troubles to Mexico’s acceptance of art created by artificial intelligence to pay taxes. For additional coverage, read the article in Tax Notes:Pandemic Spooks Salem's Tourism Tax Revenue This HalloweenPing Pong Tops Colorado’s First Month of Sports BettingDoor Swings Both Ways Denying Equitable Remedies to Tax SchemersNominee Tax Dodging Scheme BackfiredMexico Accepts Artificial Intelligence Images to Pay TaxesIn the segment “In the Pages,” Tax Notes State Editor in Chief Jéanne Rauch-Zender talks about how (and why) to write for Tax Notes. **This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.This episode is sponsored by the D.C. Bar. For more information, visit dcbar.org. *** CreditsHost: David D. Stewart Executive Producers: Jasper B. Smith, Faye McCray Showrunner: Paige Jones Audio Engineers: Derek Squires, Jordan Parrish Guest Relations: Nicole Wilder

Miller & Chevalier member Loren Ponds shares her journey from Georgetown University Law Center to the OECD to Capitol Hill, where she worked on the 2017 tax law, and what she learned along the way.For additional coverage, read the article in Tax Notes "Walking a Unique Path: A Conversation With Miller & Chevalier’s Loren Ponds."This interview published on the Miller & Chevalier podcast tax break. In the segment In the Pages, Tax Notes Federal Editor in Chief Ariel Greenblum talks about how (and why) to write for Tax Notes. **This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes. This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.This episode is sponsored by the D.C. Bar. For more information, visit dcbar.org. *** CreditsHost: David D. Stewart Executive Producers: Jasper B. Smith, Faye McCray Showrunner: Paige Jones Audio Engineers: Derek Squires, Jordan Parrish Guest Relations: Nicole Wilder

U.S. Tax Court Chief Judge Maurice B. Foley discusses his path to the bench, the court’s new case management system, and pivoting to virtual during the coronavirus pandemic.For additional coverage, read these articles in Tax Notes:Tax Court Hopes More Practitioners Will Use Remote TrialsLearning Curves, Adaptation Predicted for Remote Tax Court TrialCoronavirus Measures Will Leave Tax Court More AccessibleTax Court Institutes Remote Hearings, E-Access to Court DocsTax Court Proposes Formal Reference to Limited AppearancesNo Easy Solutions for Electronic Access to Tax Court Documents**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole Wilder

Tax Notes legal reporter Ryan Finley discusses the IRS’s major victory in the Coca-Cola case and its future implications for transfer pricing cases.For additional coverage, read these articles in Tax Notes:U.S. Tax Court’s Coca-Cola Ruling: Early Sign of a New Approach?Tax Court Sides With IRS in Coca-Cola Transfer Pricing CaseIRS, Coca-Cola Continue Fight Over Transfer Pricing AnalysisCoca-Cola's Tax Court Petition Disputes the IRS's Transfer Pricing AdjustmentsEconomist Andrew Hughes talks about his upcoming series in Tax Notes on transfer pricing benchmarks.**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

The Tax Foundation’s Ulrik Boesen discusses the excise taxes imposed on longtime vices like alcohol and cigarettes as well as more recently developed habits. **This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.This episode is sponsored by the Graduate Tax Program at Loyola Law School. For more information, visit lls.edu/taxnotes.  ***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Tax Notes senior legal reporter Andrew Velarde and contributing editor Robert Goulder discuss the influence of the 2020 U.S. elections on the international tax world. For additional coverage, read these articles in Tax Notes:Biden’s International Tax Proposals Missing Many PiecesEU Hopes to Repair Bilateral Relationship With U.S.Biden Win Brings Hope for Progress in Global Tax TalksTaxOps SALT expert Tram Le talks about her recently published piece, “Simplification Initiatives to Reduce Burdens for Remote Sellers.”**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes. This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Tax Notes reporters Alexis Gravely and Jonathan Curry discuss U.S. tax policy following the 2020 presidential election, and Tax Notes senior reporter Paul Jones talks about the results of state tax ballot measures.For additional coverage, read these articles in Tax Notes:Retroactive Tax Hikes Seen as Unlikely Under Biden AdministrationElections Viewed as Opportunity for O-Zone ResetSmaller COVID Relief More Likely as Dems Underperform in ElectionCalifornia, Alaska, and Illinois Voters Reject Tax IncreasesGovernors Hold Seats, Montana Elects First Republican in 16 Years** This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes. This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.*** CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

On Tax Analysts’ 50th anniversary, CEO and President Cara Griffith reflects on the organization’s history as a longtime transparency advocate and how she plans to expand its legacy.Kim Clausing, incoming professor at the University of California, Los Angeles Law School, talks about her upcoming Tax Notes piece, “Five Lessons on Profit Shifting From the US Country by Country Data.”For additional coverage, read these articles in Tax Notes:Reflections on Thomas F. Field: Speaking on the Public InterestTax History: Talking Tax: How We Stumbled Into PodcastingJournalists and Lawyers Report the News: A Little Help From My FriendsSCOTUS Success: Tax Analysts’ 1989 Transparency Triumph** This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes. This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.*** CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Five years ago, the OECD released its final report on the base erosion and profit-shifting project. Tax Notes Talk host David D. Stewart chats with Deloitte’s Bob Stack, who represented the U.S. government at the OECD’s BEPS talks, about his thoughts on the project’s outcome and its effect on the OECD’s current work to overhaul the global tax system for the digital age. For additional coverage, read these articles in Tax Notes:BEPS 5 Years Later: Action 1 and the Quest to Tax Digital ActivityBEPS 5 Years Later: Tax Transparency as the Global NormBEPS 5 Years Later: Practitioners Give MLI’s Effectiveness Mixed ReviewsBEPS 5 Years Later: Still No Convergence on Transfer Pricing***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Tax Notes State Editor in Chief Jeanne Rauch-Zender talks with Amy Vetter, a keynote speaker and presenter, on how to survive – and thrive – personally and professionally despite the unique challenges presented by the coronavirus pandemic. In the segment In the Pages, Tax Notes Executive Editor for Commentary Jasper B. Smith chats with reference attorney Linda Friedman about the new Document Comparison tool available to Tax Notes readers.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Tax Notes Talk host David D. Stewart chats with Tax Notes chief correspondent Stephanie Soong Johnston and Tax Notes contributing editor Nana Ama Sarfo about recent developments on the OECD’s work to rebuild the international corporate tax system for the digital age. For additional coverage, read these articles in Tax Notes:G-20 Ministers Greenlight New Deadline for OECD Global Tax AccordOECD Now Aiming for Global Corporate Tax Reform Deal by Mid-2021EU Will Respect New OECD Deadline for Reaching Global Tax DealOECD Chief to Push G-20 Ministers to Step Up on Global Tax DealCountries Push U.S. to Curb BEAT in OECD Minimum Tax ProposalBEPS 5 Years Later: Action 1 and the Quest to Tax Digital Activity***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Tax Notes contributing editor Marie Sapirie talks with American University tax professor Caroline Bruckner about the lack of consideration by Congress on how the U.S. tax code affects women-owned businesses and what can be done.For additional coverage, read Marie Sapirie's analysis in Tax Notes:A Seat at the Tax Hearing Table for Women-Owned BusinessesIn the segment In the Pages, Tax Notes Executive Editor for Commentary Jasper Smith chats with the 2020 winner of the Christopher E. Bergin Award of Excellence in Writing, Alex Zhang of Yale Law School, about his winning paper, “The State and Local Tax Deduction and Fiscal Federalism.”***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Tax Notes contributing editor Joseph J. Thorndike and University of Iowa law professor Andy Grewal take a closer look at the The New York Times reporting on President Trump’s tax returns. For additional coverage, read these articles in Tax Notes:Trump Disputes Reports, Claims He's Paid ‘Millions’ in Income TaxesTrump Tax Revelations Spur Fresh Calls for IRS, Tax ReformsTrump's Seven Springs Property Could Be Subject to SALT CapTrump Tax Returns Call Consulting Fees Into QuestionTrump Tax Reveal Puts Spotlight on Organization's Business Practices***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Tax Notes reporter Nathan J. Richman talks with outgoing IRS Criminal Investigations division Chief Don Fort about his decades-long career with the tax agency, his plans for retirement, and the future of the division.For additional coverage, read these articles in Tax Notes:Incoming CI Chief Plans New Law Enforcement NetworkAnother Longtime CI Veteran Will Be Next Division ChiefPractitioners Say Fort Is Leaving CI Better Than He Found ItCI Chief Fort Retiring at End of SeptemberCriminal Tax Investigators Learning to Cope With CoronavirusIn the segment In the Pages, Tax Notes State Editor in Chief Jéanne Rauch-Zender chats with Lynn A. Gandhi, a partner and business lawyer with Foley & Lardner LLP, about her recent piece, “The Broad Reach of Michigan’s Industrial Processing Exemption.”***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Tax Notes contributing editor Roxanne Bland chats with Donnie Charleston, the public policy and advocacy director of the nonprofit E Pluribus Unum, about how state and local tax policies can exacerbate racial inequity and what some communities are doing to address it. For more about the intersection of U.S. tax policy and racial wealth inequality, check out our podcast episode, "The Tax Code and Economic Justice in America."***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Allison Christians, the H. Heward Stikeman Chair in Tax Law at McGill University, tells Tax Notes Executive Editor for Commentary Jasper Smith about her principles for writing good papers in law school and beyond.For additional coverage, read Christians's paper, "Really Basic Rules for Writing Good Papers in Law School."***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Tax Notes Today International Editor in Chief David D. Stewart talks with Tax Notes reporters Jonathan Curry and Alexis Gravely about the tax policies proposed by President Trump and Democratic presidential candidate Joe Biden.For additional coverage, read these articles in Tax Notes:GOP Takes Subdued Victory Lap on TCJA at Republican ConventionPayroll Tax Deferral for Federal Employees Prompts CriticismBiden Tax Agenda Gets Brief Nods at Democratic ConventionTrump on the Hunt for Solutions to Payroll Tax Memo ProblemsBiden Would Fund Caregiving Plan by Cutting Like-Kind ExchangesBiden Wants to ‘Build Back Better’ With Business Tax ChangesIn the segment In the Pages, Tax Notes Federal Editor in Chief Ariel Greenblum chats with Tax Notes contributing editor Benjamin M. Willis about the piece he coauthored, “Biden-Harris’s High Hopes for Mitigating Tax Rate Disparities.”***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Francine J. Lipman, a law professor at the University of Nevada, Las Vegas, talks with Darrick Hamilton, a stratification economist and the New School’s incoming Henry Cohen Professor of Economics and Urban Policy, about the intersection of U.S. tax policy and racial wealth inequality.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Tax Notes senior reporter Paul Jones talks with Richard C. Auxier, senior policy associate at the Urban-Brookings Tax Policy Center, about tax issues raised by the gig economy and how policymakers are working to address them. Note: This episode was recorded prior to a California court decision mandating Uber and Lyft to reclassify drivers in the state as employees. For additional coverage, read these articles in Tax Notes:California Chamber Backs Labor, Payroll Tax Exemption for App-Based CompaniesLabor, Payroll Tax Law Exemption for App-Based Companies on California BallotBusinesses, Lawmakers Urge Suspension of Pending Tax PoliciesRide-Sharing Companies Fight California Labor Law on 2 FrontsTax Pros Seek Clarity on California Insurance Mandate, Employment Law California FTB Mulls Gig Economy Tax ChallengesCalifornia Governor Signs Employment Reclassification LawIn the segment “In the Pages,” Tax Notes Executive Editor for Commentary Jasper B. Smith interviews Tax Notes contributing editor Nana Ama Sarfo about her recent piece, “Rwanda Leading African Sustainable Investment Drive.”***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Tax Notes legal reporter Nathan J. Richman talks with IRS Chief Counsel Michael J. Desmond about pivoting to virtual settlement days amid the coronavirus pandemic. For additional coverage, read these articles in Tax Notes:Lessons From Virtual Settlement Days Could Help Future EventsWork-From-Home Technology Comes With New Privilege ConcernsVirtual Settlement Days Will Continue, IRS SaysIRS Collection Officials Seeing Settlement Day BenefitsIRS Considering Long-Term Benefits of Settlement Conference DaysIRS Settlement Conference Day Guide Implies Timing Flexibility***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Tax Notes chief correspondent Stephanie Soong Johnston and legal reporter Ryan Finley discuss Ireland and Apple Inc.’s state aid win with law professors Ruth Mason of the University of Virginia and Stephen Daly of King’s College London.For additional coverage, read these articles in Tax Notes:Ireland’s Reputation Harmed by Apple State Aid InvestigationWill the EU Commission Cut Its Losses After the Apple Decision?Crunch Time: What the Apple Decision Means for Global Tax ReformEU Court Rules Against Commission in Apple State Aid CaseNeither Apple nor Ireland on Hook for Any Escrow Fund LossesIn the segment "In the Pages Sneak Peek," Tax Notes Federal Editor in Chief Ariel Greenblum chats with Alan I. Appel, director of the international tax program at New York Law School, about his recent piece, "The Hidden Marriage Penalty Inside the TCJA."***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Tax Notes reporter Alexis Gravely talks with Edward Karl, vice president of taxation at the American Institute of CPAs, about tax changes made and considered by Congress in the wake of the COVID-19 pandemic. For additional coverage, read these articles in Tax Notes:Don’t Count Out PPP Deductibility, Senate Republicans SaySenate Coronavirus Relief Package Faces Uphill BattleSenate Relief Package Expands PPP, Extends Tax CreditsAICPA Calls for PPP Clarity in Next Round of Virus ReliefSmall Businesses Need a ‘Future-Proof’ Tax System, AICPA Says***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Tax Notes contributing editor Robert Goulder talks with Steven A. Dean, faculty director of New York University School of Law’s graduate tax program, about the intersection of racial diversity and U.S. international tax policy. For additional coverage, read Dean's piece in Tax Notes: FATCA, the U.S. Congressional Black Caucus, and the OECD BlacklistIn the segment "In the Pages Sneak Peek," Tax Notes Executive Editor for Commentary Jasper B. Smith chats with Lucas de Lima Carvalho, an international tax law professor at the Brazilian Institute for Tax Law, about his recent piece, "The Trouble With 'Pillars' in International Tax Policy."***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Tax Notes reporter Carolina Vargas interviews Tax Notes State contributing editor Roxanne Bland about the emerging trend among some states to tax digital advertising. For additional coverage, read these articles in Tax Notes:D.C. Council Passes Digital Ad Tax in First Budget VoteDigital Advertising Taxes Trigger Foreign Commerce Clause ConcernsMaryland Governor Vetoes Digital Ad Tax BillAnother New York Lawmaker Pushes for Digital Ad TaxDigital Advertising Tax Proposals: Revenue Booster or Unconstitutional?New York Lawmaker Proposes Digital Advertising TaxNebraska Lawmaker Pushes for Digital Ad Tax***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Kelly Phillips Erb, the managing shareholder of Erb Law Firm PC, known as @taxgirl on Twitter, talks to Tax Notes reporter Jonathan Curry about the abnormal 2020 tax season.For additional coverage, read these articles in Tax Notes:COVID-19 Shaped Tax Pros’ Business Through Filing SeasonNo Extension of July 15 Filing Deadline, IRS AnnouncesWork-From-Home Technology Comes With New Privilege ConcernsSome Tax Pros Wary of Another Return Filing ExtensionPreparers Scramble in Pandemic Adapt-to-Survive MomentBusiness of Tax: All COVID-19, All the Time for Tax WonksIn the segment “In the Pages Sneak Peek,” Tax Notes State Editor in Chief Jéanne Rauch-Zender talks with Robert Plattner about his recent piece, "Part 2: The Commerce Clause Strikes Back."***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Tax Notes International contributing editor Nana Ama Sarfo talks with Virginia La Torre Jeker, a U.S. tax attorney based in Dubai, about establishing her tax practice abroad, the challenge of balancing family life with career, and recent international tax issues.For additional coverage, read these articles in Tax Notes:Conquering Hong Kong and Dubai: A Conversation With Virginia La Torre JekerWhen Sharia and U.S. Tax Law Collide***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Lawrence A. Zelenak, the Pamela B. Gann Professor of Law at Duke University School of Law, shares his findings from watching dozens of hours of tax-related sitcom episodes. For additional coverage, read these articles in Tax Notes:Seven-Plus Decades of the Federal Income Tax in Sitcoms: An UpdateSix Decades of the Federal Income Tax in SitcomsIn the segment, “In the Pages Sneak Peek,” Tax Notes  Federal Editor in Chief Ariel Greenblum talks with Philip Wolf about his new column, A Young Practitioner's Journey.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Tax Notes legal reporter Jennifer McLoughlin interviews Richard Cram, director of the Multistate Tax Commission’s National Nexus Program, on the state of the sales tax landscape two years after the Supreme Court ruling in South Dakota v. Wayfair Inc. McLoughlin moderates a discussion between Bradley Scott, finance director of the jewelry component wholesaler Halstead Bead Inc., and Scott Peterson, vice president of U.S. tax policy and government relations at Avalara Inc.For additional coverage, read these articles in Tax Notes:Smaller Sellers Searching for Relief in Post-Wayfair WorldSmaller Businesses Struggle Most With Post-Wayfair ComplianceStates Could Lower Nexus Thresholds to Address Revenue ShortfallsStates Extend Sales Tax Deadlines, May Pass More Marketplace BillsSmall Businesses Ask Congress to Act on Remote Seller LawsMTC Finalizes 2019 White Paper on Wayfair Implementation Issues***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

In the second part of a two-episode series, Tax Notes legal reporter Kristen Parillo interviews Steve Small, one of the authors of the federal income tax regulations on conservation easements who is now in private practice, about the controversy surrounding the tax treatment of conservation easements.Read Steve Small's piece in Tax Notes: Some Dirty Realities About Syndicated Conservation EasementsFor additional coverage, read these articles in Tax Notes:Partnership Asks for Do-Over in Easement AppealIRS Win in Golf Course Easement Case OverturnedSyndicated Easement Sponsor Warns Investors of IRS AuditsConservation Easement Safe Harbor May Allow CompromiseDOJ Seeks to Leverage Conservation Easement Victory‘Tide Has Turned’ on Easement Abuse, Says Desmond***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

In the first part of a two-episode series, Tax Notes legal reporter Kristen Parillo interviews Robert Ramsay, executive director of the Partnership for Conservation, about controversy surrounding conservation easements. Read Robert Ramsay's piece in Tax Notes: A Dirty Dozen Myths About Conservation Easements and One Sad TruthFor additional coverage, read these articles in Tax Notes:Partnership Asks for Do-Over in Easement AppealIRS Win in Golf Course Easement Case OverturnedSyndicated Easement Sponsor Warns Investors of IRS AuditsConservation Easement Safe Harbor May Allow CompromiseDOJ Seeks to Leverage Conservation Easement Victory‘Tide Has Turned’ on Easement Abuse, Says DesmondIn our segment, “In the Pages Sneak Peek,” Tax Notes Executive Editor for Commentary Jasper Smith talks with Fenwick & West LLP’s Larissa Neumann about the recent piece she coauthored with James P. Fuller, "U.S. Tax Review."***This episode is sponsored by the Graduate Tax Program at LMU Loyola Law School in Los Angeles. For more information, visit www.lls.edu/taxnotes. CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Joseph J. Thorndike, Tax Notes Federal contributing editor and tax historian, discusses the Supreme Court’s recent oral arguments on the legal cases involving President Trump’s tax returns and financial records.For additional coverage, read these articles in Tax Notes:Supreme Court Weighs Limits, Burdens in Trump Tax Return CasesJudge Suggests Dismissing Trump Tax Returns SubpoenaJudge Rejects Democrats’ Delay Request in Trump Tax Return CaseSupreme Court Sets Hearing Date in Trump Tax Return LawsuitsTrump Again Asks Supreme Court to Block Financial Records ReleaseDems Urge Court Not to Give Trump Notice in NY Tax Return Quest***This episode is sponsored by the Graduate Tax Program at LMU Loyola Law School in Los Angeles. For more information, visit www.lls.edu/taxnotes. CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Tax Notes colleagues David D. Stewart and Stephanie Soong Johnston discuss how tax has influenced snacks, beards, and even legends.For additional coverage, read these articles in Tax Notes:James Bond Producers Offer New Clues on Mexican IncentivesFrom Mexico With Love: How Sony Got Millions in Incentives to Rewrite 007 FilmSony E-Mails Show Plan to Exploit 'Loophole' in Expanded Film CreditsIn the segment "In the Pages Sneak Peek," Tax Notes State Editor in Chief Jéanne Rauch-Zender talks with Marty Eisenstein about his piece, "Alexa, Is AI Taxable?"***This episode is sponsored by the Graduate Tax Program at LMU Loyola Law School in Los Angeles. For more information, visit www.lls.edu/taxnotes. CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Allison Christians, the H. Heward Stikeman Chair in Tax Law at McGill University, tells Tax Notes contributing editor Robert Goulder about her proposal for a global excess profits tax as the third pillar in the OECD’s digital economy project. For additional coverage, read her proposal in Tax Notes:It’s Time for Pillar 3: A Global Excess Profits Tax for COVID-19 and BeyondFor more background, read these articles in Tax Notes:OECD Postpones Key Meeting of Global Tax Overhaul ProjectGlobal Tax Reform Project Should Consider COVID-19, ICC SaysG-20 Global Tax Revamp More Relevant Than Ever, Minister SaysG-7 Ministers to Return to Digital Tax Agenda Once Crisis SlowsWorld Must Not Lose Focus on Global Tax Overhaul, Germany UrgesAll Tax Notes news coverage and analysis of the coronavirus pandemic is now free and accessible to the public: taxnotes.com/coronavirus-tax-coverage**CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Kate Kraus, a partner at Allen Matkins, tells Tax Notes legal reporter Eric Yauch the unexpected tax results of recent coronavirus legislation on real estate.For additional coverage, read these articles in Tax Notes:IRS Provides Distribution Relief for REITs and RICsSubstantive QIP Correction Answers Coming in Final Bonus RegsSome Taxpayers Would Rather Just Fix QIP ProspectivelyBill Would Give O-Zone Treatment to Small Businesses Hit by VirusLoss Carryback Revival Could Prompt M&A RenegotiationsO-Zone Investors Look for Additional Coronavirus ReliefIn our new segment "In the Pages Sneak Peek," Tax Notes Executive Editor for Commentary Jasper B. Smith talks with Michael Q. Cannon about his recent piece, "Double Tax Benefits in the CARES Act."All Tax Notes news coverage and analysis of the coronavirus pandemic is now free and accessible to the public: taxnotes.com/coronavirus-tax-coverage**CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Katie Quinn of McDermott Will & Emery LLP discusses the state tax implications of the COVID-19 pandemic with Tax Notes senior reporter Lauren Loricchio.For additional coverage, read these articles in Tax Notes:Telework Could Trigger Withholding Changes in Some StatesCARES Act Could Compound 163(j) Issue for Separate FilersState Bills Would Clarify Exemption of Federal Stimulus ChecksWith Tax Deadlines Extended, States Offer Relief on Fines and FeesCARES Act Interest Limitation Relief Could Have State Tax EffectsStates Could See Revenue Losses Under Federal Stimulus BillAll Tax Notes news coverage and analysis of the coronavirus pandemic is now free and accessible to the public: taxnotes.com/coronavirus-tax-coverage**CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

E. Martin Davidoff, the head of tax controversy at Prager Metis, discusses how the IRS and tax practitioners are handling tax changes and working from home as a result of the coronavirus pandemic with Tax Notes senior reporter Paul Jones.For additional coverage, read these articles in Tax Notes:Business of Tax: The Strangest Filing Season in MemoryIRS Phone Lines May Reopen as Agency Adjusts to ‘New Reality’IRS Opens the Floodgates on Tax Deadline ReliefLaw and Accounting Firms vs. COVID-19E-Services Help Desks Among Latest IRS Facilities Halted by VirusIn our new segment "In the Pages," Tax Notes Executive Editor for Commentary Jasper Smith discusses with contributing editor Ben Willis about his recently published article about former Vice President Joe Biden's COVID-19 tax plan.All Tax Notes news coverage and analysis of the coronavirus pandemic is now free and accessible to the public: taxnotes.com/coronavirus-tax-coverage**CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Omri Marian, the academic director of the Graduate Tax Program at the University of California, Irvine, discusses his role in preparing the next generation of tax professionals and virtual teaching during the coronavirus pandemic with Tax Notes reporter Jonathan Curry.For additional coverage, read these articles in Tax Notes:Virtual Paper Chase — Law Schools Transition to Online ClassesBusiness of Tax: AI Brings Uncertainty and Opportunity to Tax PracticeBusiness of Tax: International Tax, So Hot Right NowBusiness of Tax: The Emergence of the High-Tech AccountantBusiness of Tax: Why Aren’t Accounting Firms Hiring Accountants?**CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Mark Gasbarra, founder and national managing director of the firm Forte International Tax LLC, discusses how practitioners navigate the interconnected provisions of the Tax Cuts and Jobs Act with Tax Notes contributing editor Benjamin M. Willis.In an extended edition of Coming Attractions, Tax Notes Executive Editor for Commentary Jasper Smith chats with Jeffrey Wong, professor and department chair in the Department of Accounting at the University of Nevada, Reno, about his upcoming article on how CPA firms are responding to the COVID-19 crisis.**CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Nicole Kaeding, vice president of policy promotion and economist with the National Taxpayers Union Foundation, discusses the Coronavirus Aid, Relief, and Economic Security (CARES) Act.For additional coverage, read these articles in Tax Notes:CARES Act Means Crunch Time for IRS and TreasuryCARES Act Retirement Relief Appears OptionalCoronavirus Relief Act Fixes NOL Legislative QuirksCARES Act Has Negative ‘Knock-On' Effects for International TaxBusiness of Tax: Planners Should Take Care Giving CARES Act AdviceTrump Signs $2 Trillion Coronavirus Aid BillAll Tax Notes news coverage and analysis of the coronavirus pandemic is now free and accessible to the public: taxnotes.com/coronavirus-tax-coverage

Martin Sullivan, the chief economist with Tax Analysts, says the U.S. is headed toward a recession unlike any other due to the economic fallout of the coronavirus pandemic and how to find relief.For additional coverage, read these articles in Tax Notes:Economic Analysis: Emergency Tax Deferrals to Massively Boost Cash FlowEconomic Analysis: Rx for the Coronavirus EconomyNews Analysis: Who Gets Emergency Paid Leave?Revisions to House Bill Scale Back Employee Paid LeaveEmergency Legislation Mandates and Partially Subsidized Employee Paid LeaveAll Tax Notes news coverage and analysis of the coronavirus pandemic is now free and accessible to the public: taxnotes.com/coronavirus-tax-coverage

Beverly Winstead, director of the University of Maryland’s Low-Income Tax Clinic, shares how the coronavirus pandemic has affected her as a practitioner and professor with Tax Notes Executive Editor for Commentary Jasper Smith.For additional coverage, read these articles in Tax Notes:IRS Confirms: No April 15 Return Filing ExtensionVirtual Paper Chase — Law Schools Transition to Online ClassesStill No Word From IRS on Virus-Affected Service LevelsTax Pros Skeptical of IRS Payment Deferral, but Welcome ReliefTax Pros Fear Procrastination, Workload From Filing ExtensionIRS Creates New Site for Coronavirus-Related Information

Tax Notes Today reporter Aaron Davis discusses the recent state efforts to clamp down on tax-incentive bidding wars by forming a multistate compact.In the latest installment of Willis Weighs In, Tax Notes contributing editor Benjamin Willis discusses PLR 202009002 and its greater application.For additional coverage, read these articles in Tax Notes:States Push for Cooperation Over CompetitionConnecticut Looks to Join Interstate Incentives CompactQuestions Raised by Multistate Plan to Eliminate IncentivesRhode Island Lawmakers File Tax Incentive Compact BillArizona Bill Backs Interstate Tax Incentives CompactKansas-Missouri Incentives War Ends in Truce

Eric Hylton, the new head of the Small Business/Self-Employed Division at the IRS, discusses employment tax, recent high-income nonfiler visits, and data analytics. For additional coverage, read these articles in Tax Notes:IRS Expects to Hire 50 Percent More Collections Staff by Year’s EndIRS Increases Effort to Fight Abusive Microcaptive TransactionsIRS May Extend Microcap Settlement Offer to More TaxpayersIRS Looking for Promoter Links as Easement Crackdown GrowsEnforcement Push Puts Taxpayer Rights at Risk, Olson FretsOfficials Looking for Criminal Microcaptive CasesSB/SE Ramping Up Community Enforcement and VisibilityCriminal Fraud Referrals to Get Bigger Focus in SB/SEIRS Leadership Shuffle Continues With New Division Chiefs

Yue “Daisy” Dai, a professor at the Shanghai University of Finance and Economics, describes life in China during the coronavirus outbreak.She also discusses the tax policy measures the country is using to combat the pathogen. Read her piece published in Tax Notes.For additional coverage, read these articles in Tax Notes:Hong Kong Proposes Waivers for Personal and Business TaxesItaly Delays Tax Payments for Area Under Coronavirus QuarantineChina Announces Tax Measures in Response to CoronavirusHong Kong Tax Agency Suspends Services Because of CoronavirusIn the latest installment of Willis Weighs In, Tax Notes contributing editor Benjamin Willis discusses the IRS's cryptocurrency guidance and its failure to properly address tax-free forks. Read his piece published in Tax Notes.

Damien Martin, CPA and host of the Simply Tax Podcast talks about the 2020 tax filing season. For additional coverage, read these articles in Tax Notes:IRS Refund Fraud Progress May Be Undermined by Database TheftsTIGTA Spotlights IRS 2019 Filing Season Shortcomings, SuccessesPreparers Cautiously Optimistic for Normal 2020 Filing SeasonOnce More Unto the Breach: 199A Filing Season Round 2It’s Dealer’s Choice With 163(j) for Filing SeasonFiling Season Opens January 27; IRS Releases Progress ReportAlso, check out Damien's interview with Tax Notes Talk host David Stewart now on the Simply Tax Podcast.

Jason Furman, a professor at Harvard University and former chair of the Council of Economic Advisers, discusses the arguments used to back a wealth tax and suggests alternatives to reduce the wealth inequality gap in the U.S. with Tax Notes contributing editor Joseph J. Thorndike.In the latest installment of Willis Weighs In, Benjamin Willis continues his vote-to-value disparity discussion by explaining how the value of vote can affect the value of other stock rights and classes of stock and the importance of appraisals .For additional coverage, read these articles in Tax Notes:U.S. Wealth Tax Would Require More IRS Resources, Study SaysResearchers Debate Need for Taxes That Wealthy Can’t AvoidMaking a Wealth Tax Work May Require ‘Rough Justice’U.S. Well Positioned for Wealth Tax, Economist SaysA Look Ahead: Democrats to Stand Behind Wealth Taxes in 2020Warren Takes on Economists Over the Effect of Tax HikesBiden and Sanders Tax Plans Found to Overstate Revenue Gains

In honor of Tax Notes Talk’s 100th episode, we went back to the roots of what Tax Notes stands for: transparency.Tax Notes senior reporter Lauren Loricchio discussed her efforts to obtain the bid Indianapolis submitted to Amazon for HQ2 and Tax Analysts legal counsel Con Hitchcock shares the ensuing legal battle.For additional coverage, read these articles in Tax Notes:Localities Dodging Open Records Laws to Avoid Disclosure of Amazon HQ2 ProposalsGary, Indiana Offered More Than $792 Million in Failed HQ2 Bid Chicago Offered More Incentives in Second HQ2 Selection RoundVirginia Governor Signs HQ2 Incentives PackageAmazon Reaffirms Commitment to Build HQ2 in VirginiaIndiana Can Shield HQ2 Bid From Disclosure Under Advisory Opinion 

Tony Nitti, a tax partner at RubinBrown LLP, discusses the final rules on Opportunity Zones and his observations of the program in action with Tax Notes senior legal reporter Stephanie Cumings. For additional coverage, read these articles in Tax Notes:Confusion Looms About Which Set of O-Zone Regs to ApplyCollateral Problems Could Arise From O-Zone Transition RuleO-Zone Regs Include Curveball on Improvements to PropertyO-Zone Investment Numbers Could Be Vast UnderestimateO-Zone Safe Harbor Provision May Need ClarificationO-Zone Rules Applicability Date Raises Dilemma for InvestorsConsolidated Group Rules Seen as Welcome Addition to O-Zone RegsFinal O-Zone Regs Include Several Taxpayer Wins

In part 2 of her interview with Tax Notes senior reporter William Hoffman, former National Taxpayer Advocate Nina Olson discusses her ongoing fight for taxpayer rights and the upcoming fifth International Conference on Taxpayer Rights in South Africa.For additional coverage, read these articles in Tax Notes:IRS Free Tax Return Preparation Remains Out of ReachPreparers See Benefits of Form 1040-SR, but Maybe Not for ThemPolitically Active Exempts May Have Escaped IRS PenaltiesA Look Ahead: Focus on Low-Income, ESL Taxpayers in IRS Overhaul, Advocates SayEnforcement Push Puts Taxpayer Rights at Risk, Olson Frets

Nina Olson, who retired as the National Taxpayer Advocate six months ago, talks about her new nonprofit and the need for Treasury to soon name her permanent successor. This is part 1 of her interview with Tax Notes senior reporter William Hoffman. For additional coverage, read these articles in Tax Notes:IRS Free Tax Return Preparation Remains Out of ReachTaxpayer Advocate Stresses Link Between IRS Enforcement, ServiceA Look Ahead: Focus on Low-Income, ESL Taxpayers in IRS Overhaul, Advocates SayEnforcement Push Puts Taxpayer Rights at Risk, Olson FretsRettig Names Acting National Taxpayer AdvocateOlson Bids Adieu, Leaving ‘Big Shoes to Be Filled’In Willis Weighs In, Tax Notes contributing editor Ben Willis discusses vote-to-value disparity related to his article.

Tax Notes contributing editor Robert Goulder discusses the decades-old North American Free Trade Agreement (NAFTA), the new U.S.-Mexico-Canada Agreement (USMCA), and what these agreements mean for the future of tariffs and trade in North America.Read Goulder's viewpoint on the subject: Hello, USMCA, Haven't We Met Before?For additional coverage, read these articles in Tax Notes:USMCA Wins Overwhelming Approval in U.S. SenateU.S. Congress Looks to Roll Back Executive Tariff AuthorityMexican Senate Passes USMCA With Little OppositionTariff Threats Not a Roadblock to USMCA, Lighthizer SaysUSMCA Unlikely to Be Finalized in July, U.S. Senators Say 

Reuven Avi-Yonah, a professor at the University of Michigan Law School, reviews the arguments raised in Altera v. Commissioner and predicts where the case might go with Tax Notes legal reporter Ryan Finley. For additional coverage, read these articles in Tax Notes:A Look Ahead: High-Stakes Transfer Pricing Disputes to Continue in 2020IRS Will Continue Altera Fight in Other Circuits if NeededNinth Circuit Rejects En Banc Review of AlteraNinth Circuit’s Altera Decision Didn't Cause a Circuit SplitAltera Seeks Rehearing of Cost-Sharing DisputeAltera Beefs Up Legal Team in Cost-Sharing Dispute

Tax Notes's Jeremy Scott, Stephanie Cumings, and Andrew Velarde review what happened with tax legislation and guidance in 2019 and what lies ahead in 2020.For additional coverage, read these articles in Tax Notes:Conservatives Worry TCJA Could Be Death Blow to Future Tax CutsSenate Sends $426B in Tax Cuts to Trump's DeskA Look Ahead: Democrats to Stand Behind Wealth Taxes in 2020A Look Ahead: Eyes Still on TCJA International GuidanceA Look Ahead: Parking Regs Should Address Fair Market ValueA Look Ahead: Carried Interest and Form Changes Will Be Focus for Partnerships

Tax Notes reporters recount some of the quirkiest tax stories they encountered in 2019.For additional coverage, read these articles in Tax Notes:Did World’s Oldest Woman Evade Both Death and Taxes?Horse Business Deductions Can’t Survive Dead HorseArizona Governor Pulls Tax Breaks for Nike Over Canceled Shoe LineExecutors Reap Millions in Fees on Tax Cheat Helmsley’s Estate

Tax Notes reporters Stephanie Johnston and Ryan Finley provide an update on the OECD’s work to find a multilateral solution on the taxation of the digital economy.For additional coverage, read these articles in Tax Notes:U.S. Calls for Broader Scope, Narrower Nexus for Global Tax DealEU Parliament Calls for One Voice in OECD Global Tax TalksOECD Aims to Publish Global Tax Reform Analysis in Early 2020Countries Fear Opportunity Cost of U.S. ‘Safe Harbor’ ProposalThe U.S. 'Safe Harbor' Proposal: Rocking the OECD’s Pillar 1 Boat?Business Groups Urge Aggregate Approach to Pillar 2***This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Tax Notes chief correspondent Amanda Athanasiou discusses with Eversheds Sutherland partner Kriss Rizzolo the dearth of women in senior roles in tax law. Rizzolo describes her own experience climbing the ladder and how to support other women who are doing the same.  For additional coverage, read Athanasiou's article in Tax Notes:Why Women Are Still Leaving Tax, and What to Do About ItIn Willis Weighs In, Tax Notes contributing editor Ben Willis answers carried interest questions related to his article with Executive Editor for Commentary Jasper Smith.

Joe Myszka, a partner at DLA Piper, discussed the proposed rules on cloud computing transactions with Tax Notes legal reporter Kristen Parillo.For additional coverage, read these articles in Tax Notes:Treasury Wants Input on Need for Cloud Transaction Sourcing RulePractitioners Throw Shade at Cloud Regs' Digital Content RuleCPA Questions Scope of Cloud Computing RegsTreasury’s Proposal on Digital Content Sales May Cause ProblemsProposed Regs Classify Cloud Computing TransactionsOMB Completes Review of Cloud Computing RegsSky Clears for Cloud Computing Regulations***This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Fasten your safety belts. Jeremy Cape of Squire Patton Boggs explains the U.K.’s Air Passenger Duty (APD) and one group’s proposal to impose a frequent flyer levy.For additional coverage, read these articles in Tax Notes:Come Fly With Me, But Not Too FrequentlyGerman Airline Tax Prepared for Takeoff9 European Countries Unite in Push for EU Aviation TaxBrazilian Government to End $18 Fee on International FlightsTrade Group Advises Switzerland to Forgo Aviation Carbon TaxIn Willis Weighs In, Tax Notes contributing editor Ben Willis continues to discuss business purpose hurdles related to his article on the principle purpose threshold with Executive Editor for Commentary Jasper Smith.Please reach out to Ben with questions at ben.willis@taxanalysts.org.

Scott Peterson — South Dakota’s former sales tax director and the Streamlined Sales Tax Governing Board’s first chief — discusses post-Wayfair issues, the current controversy in Kansas, and the gig economy with Tax Notes chief correspondent Amy Hamilton.For additional coverage, read these article in Tax Notes:ACMA Compiling Remote-Seller Testimony to Spur Federal LegislationAICPA Paper Will Focus on Small Marketplace Seller Income TaxesKansas Revenue Secretary: AG's Wayfair Opinion Creating ConfusionKansas Governor Brushes Off Objections to Wayfair NoticeKansas Attorney General Declares Void DOR’s Wayfair ApproachIssues Over Wayfair Reference to ‘Undue Burden’ Coming to the Fore***This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Gabriel Zucman, an economics professor at the University of California, Berkeley, discusses wealth and inequality in America with Tax Notes contributing editor Nana Ama Sarfo. He co-authored the book The Triumph of Injustice: How the Rich Dodge Taxes and How to Make Them Pay with Emmanuel Saez.For additional coverage, read these articles and opinion pieces in Tax Notes:A Better Alternative to Wealth TaxesThe Zucman Mandate: Life Without VATTax History: Saez and Zucman Exaggerate Redistributive Impulse in U.S. Tax HistoryWealth Tax Comparisons to Estate Tax ‘Not Fair,’ Panelist SaysU.S. Well Positioned for Wealth Tax, Economist SaysEconomic Analysis: Risking the Wrath of 900 Billionaires

Tax Notes reporter Ryan Finely summarizes the OECD’s pillar 2 consultation draft and BDO’s Monika Loving provides her take on the proposal. For additional coverage on pillar 2, read these article in Tax Notes:BEPS 2.0 Work Must Remove Unilateral Taxes, Tech Firms Tell OECDEU Divided Over GLOBE Minimum TaxOECD Calls for Design Advice on GLOBE Minimum Tax ProposalOECD’s Minimum Tax Work Has a Long Way to Go, Experts SayAgreement on BEPS 2.0 Expected in June 2020, OECD Tax Chief SaysOECD Sets Course Toward Global Digital Tax Deal by 2020In Willis Weighs In, Tax Notes contributing editor Ben Willis discusses business purpose and principle purpose threshold with Executive Editor for Commentary Jasper Smith.For additional coverage on business purpose and principal purpose threshold, read these Willis Weighs In columns in Tax Notes: Principal Purpose: Treasury’s Disappointment in the TCJA

Martin Hearson, the international tax program lead at the International Center for Tax and Development, discusses how the OECD’s work on taxation of the digital economy affects developing countries. Listen to our previous episode for a primer on Pillar 1 and the business perspective from EY’s Barbara Angus.  ***This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Former Tax Notes reporter Asha Glover interviews Jay Soled, a professor at Rutgers Business School, about his proposal for a value tax on publicly traded U.S. corporations. Soled co-authored the proposal in Tax Notes with Rutgers Business School Professor Dan Palmon.

Joseph Thorndike, director of the Tax History Project, explains the history of estate and inheritance taxes and how they became so unpopular.For additional coverage, read these article in Tax Notes:Tax History: The Century of the Estate Tax: Made for Revenue, Not RedistributionTax History: The Not-So-Puzzling Unpopularity of the Estate TaxTax History: When Estates Were (Almost) Taxed as Income

Barbara Angus, global tax policy leader at EY, shares her thoughts on the OECD’s Pillar 1 consultation draft after Tax Notes chief correspondent Stephanie Johnston provides an update on its proposed profit allocation and nexus rules.For additional coverage, read these article in Tax Notes:G-20 Ministers Call for Agreement on BEPS 2.0 Outline in JanuaryAgreement on BEPS 2.0 Expected in June 2020, OECD Tax Chief SaysAfrican Tax Officials Back OECD's Latest BEPS 2.0 PushOECD Proposal Leaves Taxpayers Anxious for DetailsOECD Unified Approach Proposes Sharp Break With Current SystemCertainty at Core of Digital Proposal, OECD Tax Chief SaysOECD Sets Course Toward Global Digital Tax Deal by 2020

In part 2 of an interview with former IRS Commissioner John Koskinen, Tax Notes Today senior reporter William Hoffman and Koskinen discuss President Trump’s tax returns, transparency, and whistleblowers. For additional coverage, read these article in Tax Notes:No Interview Yet Between Neal and IRS WhistleblowerTreasury IG to Review Handling of Trump Tax ReturnsHouse Lawyers to Interview Trump Tax Audit WhistleblowerTrump Audit Meddling Claim Deepens Questions About Whistleblower***This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

In part 1 of an interview with former IRS Commissioner John Koskinen, Tax Notes Today senior reporter William Hoffman and Koskinen discuss IRS resources, enforcement, and taxpayer services. For additional coverage, read these article in Tax Notes:IRS Rules New Cryptocurrency From Hard Forks Is TaxableIRS Exams Focus on EITC Claims, Not Poor, Inspector General SaysIRS Budget Reduced Billions in Employment Tax CollectionsSmall Business Enforcement Gets Fresh Focus From New IRS Bosses

Grace Perez-Navarro, the deputy director of the OECD’s Center for Tax Policy and Administration, discusses the findings of the organization’s recent report on tax morale—the willingness of companies and individuals to pay taxes—with Tax Notes Today International chief correspondent Stephanie Soong Johnston in London.For additional coverage, read these articles in Tax Notes:OECD Highlights Taxpayer Morale as a Major Factor in ComplianceTax Morale Could Be Key to Domestic Resource Mobilization***This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Tax Notes Today State legal reporter Andrea Muse chats with Donald Williamson, the director of the graduate tax program at American University’s Kogod School of Business, about a New York resident tax credit case and his argument for the U.S. Supreme Court to hear it.For additional coverage, read these articles in Tax Notes:New York’s Denial of Credit Is Unconstitutional, Taxpayers ArgueNew York Urges Supreme Court to Reject Resident Credit CaseOrganizations Urge Supreme Court to Hear New York Credit CaseTaxpayers Ask Supreme Court to Review New York's Tax Credit DenialNew York High Court Rejects Challenge to Credit Denial***This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Pascal Saint-Amans, the director of the OECD's Center on Tax Policy and Administration, shares the latest on efforts to address the tax challenges of the digital economy with Tax Notes Today International chief correspondent Stephanie Soong Johnston in London.For additional coverage, read these articles in Tax Notes:Certainty at Core of Digital Proposal, OECD Tax Chief SaysUnilateral Actions to Tax Digital Now Diluted, OECD Chief SaysIreland Can’t Rely on Its Tax Allure After BEPS 2.0, Group WarnsU.S. and France Strike Compromise Over Digital Services TaxG-20 Leaders Greenlight OECD BEPS 2.0 RoadmapOECD Sets Course Toward Global Digital Tax Deal by 2020***This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Tax Notes Talk host David Stewart catches up with Jeremy Cape of Squire Patton Boggs in London about the current state of Brexit.For additional coverage, read these articles in Tax Notes:The U.K. Conservative Party’s Paucity of Tax Policy ThinkingJohnson’s Election Call Rejected as MPs Approve Brexit BillMPs Win Control of Agenda in Move to Block No-Deal BrexitJohnson Defends Plan to Shut Parliament Weeks Ahead of BrexitU.K. Prime Minister-Elect Johnson Urged to Back Businesses***This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Tax Notes Today Federal reporters Jad Chamseddine and Asha Glover outline the tax issues Congress will likely tackle this fall.  For additional coverage, read these articles in Tax Notes:Stalled Retirement Bill Causing Frustration in SenateTask Force Results Shed Little Light on Extenders FutureDebt Limit, Budget Caps Bill Heads to Trump’s DeskGillibrand Drops Out of Presidential Race Ahead of DebatesMore Democratic Candidates Eye Capital Gains Tax Hike

Francois Chadwick, Uber’s vice president of finance, tax, and accounting, details the ride-sharing company’s proposal on international tax rules for the digital economy.***This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Tax Notes Today State reporters Lauren Loricchio and Aaron Davis recap the biggest tax trends to emerge from state legislatures in 2019 and preview what’s to come.For additional coverage, read these articles in Tax Notes:Massachusetts Enacts Budget Revamping Remote Retailer ObligationsWisconsin Governor Signs Budget Including Income Tax CutsRoundup: Marketplace Facilitator Laws Enacted in 33 StatesIllinois Lawmakers End Session With Tax Bills, Balanced BudgetIllinois Graduated Income Tax Heads to VotersMinnesota Lawmakers Compromise on Federal Conformity, Tax Cuts

Francine J. Lipman, the William S. Boyd Professor of Law at the University of Nevada, Las Vegas, discusses her role as a Nevada state tax commissioner and her recent column in Tax Notes on U.S. Supreme Court Justice Ruth Bader Ginsburg’s pro bono tax work.***This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Tax Notes Today reporters Kristen Parillo and Jad Chamseddine discuss the Senate’s recent action on several tax treaties after a nearly decade-long delay. For additional coverage, read these articles in Tax Notes:Senate Finishes Tax Protocols, Sets Sights on Treaties NextSenate Ratifies Spain Protocol, More to ComeSenate Doesn’t Want Further Debate on Tax TreatiesTax Treaties Advance in Senate With Little BacklashTreaties Expected to Advance Despite Amendments ScareNegotiations Over Paul’s Hold on Tax Treaties Break Down

Tax Notes Today legal reporter Eric Yauch delves into the recent decisions by several private equity firms to convert to corporations in wake of the Tax Cuts and Jobs Act.For additional coverage, read these articles in Tax Notes:Carlyle’s ‘Full C Corp’ Conversion Differs From OthersPrivate Equity Firms Are Converting to Corps, Sort OfApollo Joins Fund Manager Bandwagon by Converting to C CorpC Corp Conversions Advance, Others Still Mulling Decision***This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Tax Notes Today reporters Ryan Finley and Jad Chamseddine review several European countries’ unilateral approaches to taxing the digital economy and the U.S. reaction. For additional coverage, read these articles in Tax Notes:France Confident of G-7 Digital Taxation Deal Despite U.S. ProbeFrench Senate Passes DST Despite U.S. Tariff ThreatsU.K. Proposes Draft DST Legislation Containing Double Tax ReliefLawmakers Warn of Effect of Digital Services Tax on Trade PactsTrump Orders Investigation of French Digital Services Tax***This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Jonathan Curry and Andrew Velarde discuss the draft regulations Tax Notes obtained from the Office of Information and Regulatory Affairs.For additional coverage, read these articles in Tax Notes:New OIRA Drafts Reveal Tweaks to TCJA GuidanceOIRA Leadership Shuffle Opens Door to Tax Reg Review Shake-UpOIRA’s Tax Reg Reviews Remain a ‘Black Box’ Despite Draft RegsSpotlight on OIRA’s Review Process Eases Politicization ConcernsOIRA’s Imprint on Tax Regs Revealed in New Cache of Documents***This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Jared Dunkin, head of tax at a Washington, D.C.-based publicly traded multinational, discusses the role practitioners have in mentoring and developing tax professionals. Dunkin is author of the book, Brass Tax: 14 Actionable Insights to Power Your Success.***This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Steve Dixon and Kevin Kenworthy of Miller & Chevalier discuss the U.S. Supreme Court's recent decision to uphold Auer deference in Kisor v. Wilkie and what it means for the Treasury and the IRS.For additional coverage, read these articles in Tax Notes:Auer Deference Survives, But ‘Neutered’ and ‘Zombified’U.S. Supreme Court Decision on Auer Won’t Affect Tax CasesConservative Justices Question Feasibility of Auer’s SurvivalGorsuch Dissent Could Signal Beginning of the End for Chevron

Kristen Parillo and Ryan Finley discuss the Ninth Circuit's new opinion in Altera v. Commissioner upholding a regulation requiring that parties to a cost-sharing arrangement share stock-based compensation.For additional coverage, read these articles in Tax Notes:Altera, the Sequel — Jurisprudence Catches Up With BEPSAltera Decision Revives Commensurate With Income StandardNinth Circuit Again Upholds Cost-Sharing Regs in Altera

Tax Notes Today State reporter Paige Jones discusses the developments in states since the U.S. Supreme Court's June 21, 2018, decision in South Dakota v. Wayfair Inc.See the Tax Notes Nexus Tracker and these articles for more coverage:One Year Later: Experts Discuss Aftermath, Future Impact of WayfairNo New Streamlined Member States a Year After WayfairNCSL SALT Task Force Contemplates Its Future Post-WayfairRemote Sellers Seeking Relief as States Shift to Marketplace LawsNew Hampshire Wages War Against Wayfair

Stephanie Johnston discusses the G-20 finance ministers' reaction to the OECD's workplan to achieve consensus on taxing the digital economy. The G-20 finance ministers met recently in Fukuoka, Japan. For more coverage, read these articles in Tax Notes:G-20 Finance Ministers Endorse OECD Roadmap for Digital EconomyFrance Aims for G-7 Consensus to Set Stage for Digital Tax DealOECD Sets Course Toward Global Digital Tax Deal by 2020Countries Greenlight OECD Digital Tax Workplan

Professor Yair Listokin of Yale Law School discusses the ways that tax policy has affected past recessions and how it may help or hurt in the next one. He also takes a look at the Tax Cuts and Jobs Act from a macroeconomic tax perspective. Listokin is the author of the book, Law and Macroeconomics: Legal Remedies to Recessions. 

Eric Yauch and Andrew Velarde highlight the major themes that came up at the American Bar Association Section of Taxation meeting in Washington, including interesting insights into recent and coming regulations. For more coverage of the ABA meeting, read these articles in Tax Notes:IRS Considering More Safe Harbors in O-Zone RulesPartnerships Can Defer Section 1231 Gain Under O-Zone RulesTreasury Carefully Considering Interest Definition in Final RulesTriple Net Lease Changes Likely in Final 199A Safe HarborIRS Won’t Be as Forgiving of TCJA Comment DeadlinesWilkins Predicts Temporary Regs Will Disappear From RulemakingTreasury, IRS Open to Suggestions on PTI SimplificationU.S. Officials Urging Delay of DSTs as Negotiations ContinueLooming Tax Court Trial Will Test Economic Substance DoctrineBridging the Guidance Enforcement Gap Is IRS Priority

Andrew Velarde talks to Joe Calianno of BDO about the pending final guidance on the global intangible low-taxed income provision enacted as part of the Tax Cuts and Jobs Act, and Paige Jones talks to Scott Smith of BDO about the state responses to GILTI.

At a breakfast panel of the American Bar Association Tax Section meeting in Washington, David Stewart talks to Lilian Faulhaber and Will Morris about the taxation of the digital economy. Lilian Faulhaber is a professor at Georgetown Law, and Will Morris is the deputy global tax policy leader at PwC.

Tax Notes Today Legal Reporter Eric Yauch discusses the final section 199A regulations and the IRS's FAQ on the application of the new passthrough deduction.For additional coverage, read these articles in Tax Notes: IRS Sneaks ‘Nasty Surprise’ Into Expanded 199A FAQBusiness Separation Under 199A Remains a MysteryWhether a Taxpayer Qualifies for 199A Depends on Who You AskWhat Constitutes a Triple Net Lease for the 199A Safe Harbor?Rental Owners Realizing 199A Complexity as Filing Season AdvancesSeparate Business Language Tweaked in Final 199A RegsFinal 199A Rules Provide Answers to Some Structuring Questions

In a phone interview, Jonathan Curry talks to Brad Dillon of Brown Brothers Harriman about estate planning trends following the Tax Cuts and Jobs Act, as well as what keeps planners up at night ahead of the 2020 election.

Stephanie Cumings discusses the Opportunity Zone program and the highlights of the new proposed regulations.For additional coverage, read these articles in Tax Notes: O-Zone Regs May Not Totally Bar Triple Net LeasesO-Zone Regs Don’t Address Practical Tiered-Partnership IssueNew Proposed O-Zone Regs May Be the Last, Officials SayCarried Interest Benefits Curbed for Some O-Zone Investments

In part 2 of an interview with National Taxpayer Advocate Nina Olson, Tax Notes Today senior reporter William Hoffman and Olson discuss her impending retirement, her work as the national taxpayer advocate, and her future plans.

In part 1 of an interview with National Taxpayer Advocate Nina Olson, Tax Notes Today senior reporter William Hoffman and Olson discuss the filing season, the Taxpayer First Act (H.R. 1957), the disclosure of program manager technical advice, and congressional efforts to get President Trump's tax returns.For additional coverage, read these article in Tax Notes:Treasury Misses Dems’ Deadline for Handing Over Trump’s ReturnsHouse Approves IRS Reform Measure Despite Free File FightRelease of Emailed Chief Counsel Advice Dropped 17 PercentTaxpayer Advocate: IRS Using Email to Avoid Advice Disclosure

Raymond Wynman, the managing director of Global Tax Management’s International Tax practice, discusses the final rules on section 965, specifically the 965(b) basis-shifting election and the specified payment rule.

In our special April Fools' episode, Tax Notes reporters recount some of their favorite stories of tax protester arguments. 

Stephanie Johnston talks to Grace Perez-Navarro, deputy director of the OECD's Centre for Tax Policy and Administration, about its public consultation in Paris to address taxing the digital economy, and Ryan Finley and Johnston discuss the consultation document in detail.For additional coverage, read these articles in Tax Notes:Making Waves: OECD Navigates Debate on Tax Rules for Digital AgeSimplicity Is Key in OECD Anti-Base-Erosion ProposalU.S.-Style Minimum Taxation May Spread Without OECD CoordinationU.S., European Officials See Digitalized Economy Deal as LikelyOECD’s Latest Digital Tax Consultation Draws Robust ResponseOECD Tax Proposals Tackling Digital Economy Draw Mixed Reactions

Mike Minihan of BX3 Capital discusses the cryptocurrency market and its regulatory and tax environment.

William Hoffman checks in on the the first round of tax filings under the Tax Cuts and Jobs Act, including the data on refunds and the effect of the government shutdown on the filing season.For more detailed coverage, read these articles in Tax Notes:Refunds Turn Higher, but Treasury Warns of ChangesPolicymakers Debate Causes, Remedy for Tax Refund LagEconomic Analysis: Will Disappointing Refunds Derail the TCJA?IRS Recovery From Shutdown ‘Amazing,’ Rettig SaysDon’t Blame Smaller Refunds on Withholding Tables, Says TreasuryTax Refunds Turn Into Political Football as Treasury Calls FoulFiling Season Stats Down Across the Board in First IRS NumbersNeither Bang Nor Whimper, Filing Season Starts With a Grind

Kimberly Clausing, the Thormund Miller and Walter Mintz Professor of Economics at Reed College, discusses tariffs, free trade, and globalization. She is also the author of the new book, Open: The Progressive Case for Free Trade, Immigration, and Global Capital.

Richard Joslin, a consultant to EnTrustPermal, discusses how the new business loss and interest expense limitations work together and affect other code provisions.For more details, read Joslin's article in Tax Notes.

Carrie Elliot talks about the changes the Tax Cuts and Jobs Act will bring between now and 2027, including rate increases.

Eric Yauch discusses the final rules on the centralized partnership audit regime.For additional coverage, read these articles in Tax Notes:Audit Regime Raises Need for Appeals GuidancePractitioners Suggest Options for Debt Issues in Audit RegimeFinal Audit Regs Put Focus on Debt MischaracterizationFinal Audit Regs Clarify What’s In, What's Out of New RegimeNew Final Partnership Audit Rules Provide Several Clarifications

Tax Notes contributing editor Benjamin Willis examines the authority of regulators in interpreting statutory tax provisions, especially in the context of the Tax Cuts and Jobs Act as the role of regulations has become more prominent. Read Willis’s related Tax Notes article.

Robert Goulder discusses the proposal to eliminate the EU's unanimity requirement for tax directives and what that would mean for tax policy. For additional coverage, read these articles in Tax Notes:Should the EU Scrap the Unanimity Requirement?Cost of Unanimity on Tax Rules Will Only Increase, Group SaysProposal to End EU Unanimity Requirement Coming by Year-EndEU's Moscovici Says Commission to Propose Qualified Voting on Tax MeasuresNews Analysis: Is the End Near for the Unanimity Rule for EU Tax Issues?

Jonathan Curry takes a fresh look at the tax regulatory review agreement between the Office of Management and Budget and Treasury now that the process has had time to play out.For further coverage, read these articles in Tax Notes:OIRA Review of Tax Regs Presses on Despite ShutdownA Look Ahead: Treasury, OIRA to Chart New Territory as Final Regs Flood InTreasury, OIRA Still at Odds Over When Tax Regs Merit ReviewTax Regs Deemed Significant Skyrocket Under New Agenda

Jeremy Scott, Stephanie Cumings, and Andrew Velarde provide a review of what happened with tax legislation and guidance in 2018 and what's ahead in 2019.For additional coverage, read these articles in Tax Notes:Neal Planning for TCJA Hearing by January’s EndA Look Ahead: Legislators Queuing Up Multiple Retirement BillsA Look Ahead: Healthcare Tax Policy Could Stem From Divided CongressHouse Passes GOP Tax Bill With No Hope for EnactmentA Look Ahead: Awaiting Clarification of 199A and Audit Regime RulesA Look Ahead: Questions Abound on Exec Comp Grandfathering RuleA Look Ahead: 2019 Should See Final Bonus and Tax Accounting Regs

In the second volume, reporters highlight the quirkiest tax stories of the year.For coverage of these stories in Tax Notes, see:Meals Deduction Guidance Comes Off the Back BurnerNew Business Meals Guidance Creates Substantiation ConcernsCalifornia Pot Money Takes Long, Strange Trip to BankHistoric $5.6 Million Washington State Tax Zapper Case Dismissed Cheesecake Factory Asks for Cherry on Top

Reporters highlight the quirkiest tax stories of the year.As mentioned in the episode, here is a copy of Adolf Hitler's 1926 tax return provided to Tax Analysts.For coverage of these stories in Tax Notes, see:Court Guns Down IRS Arguments Over Deductions for Cowboy GamesHitler’s 1926 Tax Return on Sale for $125,000Cirque du Soleil Founder’s Space Flight Taxable

Emily Foster and Eric Yauch discuss some of the key elements of the recently proposed regulations on the business interest deduction limitation.For more extensive coverage, read these articles in Tax Notes:Interest Rule Leaves Securities Traders in a JamInterest Regs Muddy Partnership Debt-Equity DecisionsInterest Deduction Regs’ Antiavoidance Rule Causes ReassessmentsInterest Allocation Rules Could Wreak Havoc on GroupsInterest Regs Require Taxpayers to Decide on ‘Early Adoption’Interest Regs Raise Same Real Estate Issues as 199A RulesInterest Deduction Regs Cover More Than Just InterestInterest Regs Tackle Some Passthrough Issues, Leave Others Open

David Stewart talks to Porus Kaka at the International Taxation Conference in Mumbai about various tax issues, including India's new permanent establishment concept, taxation of the digital economy, and the effects of the Tax Cuts and Jobs Act.For related coverage, read these articles in Tax Notes:India’s Tax Chief: Digital Taxation Needs Fair Allocation RulesIndia’s New PE Scheme Limited by Unanswered QuestionsIndia Seeks Input on Digital PE for Taxing Foreign CompaniesIndia's Equalization Levy Brings In Nearly $90 MillionIndia's 2018 Budget Introduces Digital PE Rules

Jad Chamseddine and Paul Jones discuss the Wayfair decision and the long-term implications for state and foreign taxes.Listen to previous episodes on Wayfair:Navigating the Post-Wayfair WorldU.S. Supreme Court Overturns QuillFor additional coverage, read these articles in Tax Notes: Texas Bill Would Provide Statewide Local Tax Rate for Remote SellersWayfair Settlement Is a Missed OpportunitySouth Dakota and Wayfair Litigants Reach SettlementCalifornia Looks to Follow South Dakota on Remote Sales Tax EnforcementAlabama Remote Sales Tax Law Could Be Model for Other StatesCalifornia Likely to Implement Wayfair in 2019Beyond Wayfair: Implications for State and Foreign Taxes

Lauren Loricchio provides an update on Amazon's choice of two HQ2 locations: Northern Virginia and the borough of Queens in New York City.For more coverage in Tax Notes, read:Louisville Won't Release HQ2 Bid, Despite Amazon Announcement Amazon's New York City HQ2 Site Eligible for Federal Tax BreaksGeorgia First Also-Ran to Reveal Incentives Offered to AmazonAmazon to Split HQ2 Between New York City, Northern VirginiaGroup Slams Reports of Two Amazon HQ2s as 'Bait and Switch'Bezos Will Let His Heart Lead Him to Amazon's New HomePittsburgh to Appeal Order Requiring Release of Amazon HQ2 Proposal

A roundup of the November 6 midterm election results. Asha Glover and Stephen Cooper discuss what changes to look for in the new Congress, including the makeup of the House Ways and Means Committee and the tax agendas. Paul Jones and Lauren Loricchio discuss the results in the state gubernatorial races as well as the tax ballot measures approved by state voters.For more coverage in Tax Notes, see:Senators Agree on IRS Reform, Extenders as Lame-Duck PrioritiesBrady Eyes Dozens of TCJA Technical Fixes in Lame DuckWays and Means to Review Tax Extenders This WeekTax Committees Brace for Turnover in Next CongressTrump Open to Corporate Rate Increase to Get Middle-Income Tax CutNeal Wants Trump to Voluntarily Give Up ReturnsGubernatorial Winners Set to Advance Tax ProposalsVoters OK State Tax Ballot Measures on Marijuana, Income Tax CapMidterms Stifle GOP Tax Plans as Democrats Take Control in House

Jonathan Curry discusses the IRS's rules addressing strategies using trusts to sidestep the section 199A deduction limitations and claim multiple deductions.For more coverage in Tax Notes, see: 199A Regs’ Multiple Trust Rule May Invite ChallengesCreating Just One Trust for the 199A Deduction? Think AgainNon-Grantor Trusts Still Useful in TCJA PlanningIRS Drops Hammer on 199A, SALT Cap WorkaroundsIRS Likely to Trounce 199A Trust Planning Strategy

Eric Yauch discusses a provision of the Tax Cuts and Jobs Act that hasn't received a lot of attention: section 461(l), which caps excess business losses at $250,000 for individuals and $500,000 for joint filers.For more coverage in Tax Notes, see:New Loss Limitation Is on Government’s RadarNew Loss Limitation Hard to Calculate, Interpret With Other Rules

Jeremy Cape of Squire Patton Boggs discusses the tax issues arising from Brexit.For related coverage on Brexit, read these articles in Tax Notes:U.K. Tax is Lesser Concern in No-Deal BrexitU.K. Backs Customs Agents Facing Brexit Capacity ChallengeEU, U.K. Leaders Willing to Extend Brexit Transition PeriodBrexit Talks at Impasse Over Customs Backstop Proposal EU Proposes 'Least Intrusive' Customs, VAT Checks After BrexitThe U.K. Can’t Afford to Become a Tax Haven, Says Labour PoliticianEU Steps Up Complaint Against U.K. Over €3 Billion Customs FraudHMRC Warns of Customs and VAT Impact of No-Deal Brexit For more on the Jaffa Cakes and Pringles debate, see:Cake or Biscuit? Why Jaffa Cakes Excite PhilosophersThe Lord Justice Hath Ruled: Pringles Are Potato Chips

Andrew Breiner talks to practitioners about the various issues raised by state efforts to tax peer-to-peer car rentals. For related coverage, read these articles in Tax Notes:Illinois Governor Vetoes Car Sharing Bill, Proposes Own PlanStates Look to Tax the Car-Sharing IndustryAirbnb and the Sharing Economy

Andrew Velarde highlights the significant insights from the recent American Bar Association Section of Taxation meeting in Atlanta, where the Tax Cuts and Jobs Act was once again the main topic of discussion.For additional coverage of the ABA meeting, read these articles from Tax Notes:TCJA Shaping Global Discussion as Several Regs Near CompletionU.S. Antiabuse Rules, Imperfect International Tax Regs ComingTransition Tax Guidance Will Extend Transfer Agreement Due Date'Guideposts’ Revealed for R&D-intensive Business SpinoffsTreasury Clarifies 199A De Minimis Rules Have Cliff Rental Property Ownership Could Decide 199A EffectsTreasury: Qualified Improvement Property Needs Technical CorrectionBonus Depreciation Regs Unlikely to Be Finalized This Year

Amy Hamilton discusses the IRS's proposed regulations addressing workarounds to the cap on state and local tax deductions. For additional coverage of the SALT regs, read these articles from Tax Notes: California Governor Vetoes SALT Deduction Cap Workaround New York Coalition to Fight Federal SALT Regulations The Frivolous Challenge to the SALT Deduction Cap Practitioners Urge Caution in Passthrough SALT Cap Planning New Jersey Won't Scrap SALT Cap Workaround, Despite IRS Regs Treasury Receives More Than 1,500 Comments on Proposed SALT Regs Proposed Federal SALT Rules Would Close Private School Donation Strategy IRS Has Plan to Shut Down SALT Workarounds

Andrew Velarde and Alexander Lewis provide an in-depth look into the proposed regs on global intangible low-taxed income. Read Tax Notes’ latest coverage of the proposed GILTI regs: Treasury Assuages Some Concern Over GILTI Antiabuse Rule Breadth GILTI Regs Signal Business Interest Limits Might Apply Proposed GILTI Regs Could Result in Taxable Phantom Income Practitioners Bristle at GILTI Antiabuse Provision Practitioners Throw More Shade at GILTI Antiabuse Rules GILTI Regs Focus on Computations, Punt on FTC Issues

Stephanie Johnston, Robert Goulder, and David Stewart highlight the hot topics at the 72nd Congress of the International Fiscal Association recently held in Seoul. Check out these stories for coverage of the 2018 IFA Congress: EU Digital Taxation Plan Is ‘Not a Master Thesis’ OECD Makes Headway on Long-Term Answers to Tax Digital Economy OECD Finalizing Work to Enlist Digital Platforms to Collect VAT Judicial Oversight Important for GAAR Application, Judge Says Germany Wants Progress on BEPS, Minimum Effective Taxation EU Member States Remain Divided Over Digital Services Tax

Paige Jones talks to Jim Ford of Global Tax Management about how retailers are preparing to collect and remit sales and use taxes in the wake of the U.S. Supreme Court's decision in South Dakota v. Wayfair Inc.

David Stewart, Kristen Parillo, and Ryan Finley examine the Altera v. Commissioner case — everything leading up to the Ninth Circuit opinion, the withdrawal of the opinion by that court, and the status of the case now.

David Stewart and Eric Yauch delve into the details of the proposed regulations on the passthrough deduction under section 199A.

Jonathan Curry discusses the details of the new agreement between the Treasury Department and the Office of Management and Budget over authority to review tax regulations.

State Tax Notes Chief Correspondent Amy Hamilton examines the impact of federal tax reform on the states and how states are responding legislatively to the Tax Cuts and Jobs Act.

David Stewart and Ryan Finley discuss whether the Tax Cuts and Jobs Act will finally end the IRS's poor litigation record in transfer pricing cases.

Tax Notes Today Editor in Chief Brett Ferguson discusses where things are with the Tax Cuts and Jobs Act now that it's been six months since the law was enacted.

Jad Chamseddine talks to David Stewart about the U.S. Supreme Court's decision to overturn Quill in South Dakota v. Wayfair Inc. and the implications of that ruling for state tax collection on remote sales.

The director of the OECD's Center for Tax Policy and Administration, Pascal Saint-Amans, and the deputy director, Grace Perez-Navarro, sit down with Worldwide Tax Daily chief correspondent Stephanie Johnston to discuss the challenges arising from taxing an increasingly digital economy.

Andrew Velarde and David Stewart take a look back at the American Bar Association Section of Taxation May meeting and highlight the important guidance and developments that were discussed.

Andrew Velarde provides a preview of the upcoming American Bar Association Section of Taxation May meeting and the important guidance and developments that may be discussed.

Jonathan Curry and David Stewart discuss the tax planning opportunities and challenges arising from changes to the estate tax under the Tax Cuts and Jobs Act.

As tax day approaches, Tax Notes Today Editor in Chief Brett Ferguson discusses congressional efforts to reform the IRS, including the Taxpayer First Act and the 21st Century IRS Act.

In a special April 1 episode of the podcast, tax historian Joseph Thorndike and David Stewart discuss the intersection of U.S. taxes and alcohol.

Zoe Sagalow talks to David Stewart about the effect of the Tax Cuts and Jobs Act on law firms' tax practices. Her informal survey of law firms reveals they are already seeing signs of the new tax law spurring more demand for their services that could lead to increased hiring.

David Stewart talks to legal reporter Jad Chamseddine about the Wayfair case pending before the U.S. Supreme Court, which could overturn the Quill decision and lead to a major change in the taxation of online commerce.

David Stewart and Jonathan Curry discuss the complexity of measuring the impact of the tax cuts under the Tax Cuts and Jobs Act (P.L. 115-97).

David Stewart talks to Bill Parks and Reuven S. Avi-Yonah about taxing multinationals. They discuss the current state of the corporate income tax now that the Tax Cuts and Jobs Act is law and whether there is a better way to apportion income.

David Stewart talks to Lauren Loricchio about her effort to obtain through public records requests data from localities competing for Amazon’s second headquarters project. She found that the localities used various methods to avoid public disclosure of incentives offered to the company, including narrow interpretations of state open record laws and bids submitted through entities not subject to those laws.

David Stewart talks to Stephanie Johnston about the problem of taxing the digital economy and what the OECD and EU are doing to find solutions to the problem.

David Stewart, Jeremy Scott, and Emily Foster provide a legislative and regulatory preview of the year ahead now that tax reform has passed.

David Stewart and Jeremy Scott discuss the final version of the tax reform bill, which would permanently cut corporate taxes and temporarily provide relief for individuals through 2025.

David Stewart talks to Zoe Sagalow about a new estimate of inflation -- the chained consumer price index -- proposed in the House and Senate tax reform bills.

David Stewart talks to Jonathan Curry about Treasury’s removal of an analysis (Technical Paper 5) from its website on who bears the burden of the corporate tax.

David Stewart and Jeremy Scott discuss the details of the Senate version of the Tax Cuts and Jobs Act, highlighting the differences between the Senate and House bills. The modified mark of the Senate tax reform bill includes repeal of the Affordable Care Act's individual healthcare mandate and would make tax cuts for individuals temporary.

David Stewart and Jeremy Scott discuss the House Republican tax bill, the Tax Cuts and Jobs Act (H.R. 1).

David Stewart and Jonathan Curry discuss the budget reconciliation process and what it means for tax reform.

David Stewart talks to Jonathan Curry about the proposal in the “Big Six” tax reform negotiators' unified framework to tax passthrough businesses at a special rate.

David Stewart talks to Carrie Elliot, contributing editor at Tax Notes International, about carbon taxes and carbon pricing. They also discuss carbon taxes in the context of the Paris Agreement.

David Stewart talks to State Tax Today reporter Paige Jones about states pursuing alternatives to the gas tax.

Zoe Sagalow talks to Luca Gattoni-Celli about the data breach involving the IRS's data retrieval tool (DRT). After this episode was recorded, the IRS confirmed that its revised DRT was reactivated on October 1, 2017, for the 2018-2019 FAFSA form, but not for the 2017-2018 cycle. The IRS declined to provide any update about the timing or scope of the DRT's exploitation by identity thieves, including the number of victimized taxpayers. Tax Analysts will continue pursuing this story and share any new developments with our podcast listeners.

Lauren Loricchio and Maria Koklanaris discuss the rollback of the Kansas governor's tax agenda, including ending the exemption for passthroughs.