Tax Notes Talk

April Harding, former IRS director of user experience services and the mind behind the IRS 2029 Plus modernization plan, shares her insights on transforming the IRS into a more efficient entity. She discusses the importance of user experience in tax collection and customer service, emphasizing trust in government. Harding addresses privacy concerns, the challenges of staffing, and the need for empowered leadership to successfully implement changes. Her optimism for the future transformation of IRS digital services shines through as she expresses her commitment to public-sector improvement.

Karen Kelly, a former acting assistant attorney general in the Justice Department Tax Division, shares insights from her nearly 30 years as a federal tax prosecutor. She discusses the proposed dissolution of the tax division and the potential impacts on civil and criminal tax enforcement. Karen highlights staff concerns over uniform enforcement and the challenges of shifting responsibilities within the DOJ. She also reflects on her transition to private practice and the differences between defending clients and prosecuting cases, while remaining open to future government roles.

In this discussion, tax experts David Gamage, a law professor researching taxation, and Darien Shanske, a professor specializing in state tax policy, delve into their recent research on state-level wealth taxes. They outline how these taxes could effectively target intangible wealth and address inequities in current tax systems. The conversation covers historical context, constitutional challenges, and design considerations necessary for implementation. They also explore the political landscape around such reforms and why a state wealth tax may be the solution for greater fairness.

Tax Notes contributing editors Robert Goulder and Joseph Thorndike discuss the recent Nvidia deal to export chips to China, and they question its constitutionality and implications. For more coverage, read the following in Tax Notes:ANALYSIS: The Nvidia Affair: So Now We're Taxing Exports?ANALYSIS: Trump’s Nvidia Deal Is Almost Certainly Unconstitutional — Not That It MattersWhite House Eyes Replicating Nvidia Deal for Other IndustriesNvidia Deal Sparks Dismay From Tax ObserversFollow us on X:Robert Goulder: @RobertGoulderJoe Thorndike: @jthorndikeDavid Stewart: @TaxStewTax Notes: @TaxNotes**CreditsHost: David D. StewartExecutive Producers: Jeanne Rauch-Zender, Paige JonesProducers: Jordan Parrish, Peyton RhodesAudio Engineers: Jordan Parrish, Peyton Rhodes

Kathleen Walters, former IRS Chief Privacy Officer, discusses her nearly two-decade tenure at the agency and the complex data sharing deal with the Department of Homeland Security. She shares insights into her departure motivated by disagreements over privacy practices and talks about the emotional aspects of leaving a role tied to public service. As a working mom, Kathleen highlights how parenting enhances her leadership skills and the ongoing challenges of data privacy in an AI-driven world, emphasizing the importance of effective governance.

Tax Notes contributing editor Robert Goulder discusses how Pope Leo XIV’s American citizenship creates a unique tax issue and how the United States may try to avoid taxing the pope.  For more coverage, read the following in Tax Notes:Expats Eye Pope's Tax Woes as Opportunity to Ditch Worldwide TaxAnalysis: The American Pope and Citizenship-Based TaxationFollow us on X:Robert Goulder: @RobertGoulderDavid Stewart: @TaxStewTax Notes: @TaxNotes**CreditsHost: David D. StewartExecutive Producers: Jeanne Rauch-Zender, Paige JonesProducers: Jordan Parrish, Peyton RhodesAudio Engineers: Jordan Parrish, Peyton Rhodes

Tax Notes contributing editor Ryan Finley discusses the current transfer pricing landscape, including where things stand in the Facebook and Coca-Cola cases. For more coverage, read the following from Finley in Tax Notes:Analysis: The CUT Method: It's Not What It Used to BeAnalysis: The CUT Method: Same as It Ever Was?Analysis: On Periodic Adjustments, Facebook Opinion Suggests A Middle RoadAnalysis: For the IRS, Facebook Is a Reminder to Stick to the ScriptAnalysis: Medtronic II: Do the Transfer Pricing Regs Swallow Themselves? Follow us on X:Ryan Finley: @RyanMFinleyDavid Stewart: @TaxStewTax Notes: @TaxNotes**CreditsHost: David D. StewartExecutive Producers: Jeanne Rauch-Zender, Paige JonesProducers: Jordan Parrish, Peyton RhodesAudio Engineers: Jordan Parrish, Peyton Rhodes

Join Ellen Aprill, a Senior Scholar at UCLA School of Law, as she dives into the intense legal battle between Harvard and the Trump administration over tax-exempt status. She unpacks the ramifications of potential revocation on nonprofit organizations, especially concerning funding and academic freedom. Topics include the processes of tax-exempt status audits, the implications of discrimination claims, and the broader impact on institutions. Aprill also discusses navigating compliance in a rapidly shifting public policy landscape.

Steve Kralik, Managing Director at Armanino Advisory, dives into the One Big Beautiful Bill Act and its significant ramifications on state tax, especially the SALT deduction cap. He discusses the challenges states face in adapting to the new legislation, including financial implications for vital programs like Medicaid. Kralik also explores the political landscape surrounding these changes and how they might reshape state tax systems, highlighting the need for clearer regulations as lawmakers navigate this complex terrain.

Alan Cole, a senior economist at the Tax Foundation, sheds light on the One Big Beautiful Bill Act's international tax provisions. He discusses crucial reforms like GILTI, FDII, and BEAT, emphasizing their impact on multinational corporations. The conversation dives into the contrasting House and Senate perspectives, revealing how political dynamics shaped legislative choices. Cole also examines changes in U.S. tax policy, particularly modifications to the CFC look-through rule, and the rising challenges of digital services taxes for U.S. businesses.