Tax Notes Talk

Send us a textTax Notes chief correspondent Amanda Athanasiou discusses her recent investigation into the IRS's handling of Freedom of Information Act requests and trends from two decades of agency data.For more, check out the Tax Notes coverage of the IRS FOIA system:IRS FOIA Backlog Expected to GrowFOIA Appeals Fail So Often, Taxpayers See a Broken SystemThe IRS Is Getting Fewer FOIAs. Why Aren’t Response Times Improving?Follow us on X:Amanda Athanasiou: @akathanasiouDavid 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 JonesProducers: Jordan Parrish, Peyton RhodesAudio Engineers: Jordan Parrish, Peyton Rhodes

Send us a textMat Mermigousis of BDO discusses the Trump administration’s ever-changing tariff policies and what they may mean for U.S. businesses. For more coverage, read the following in Tax Notes:Trump Pauses Tariff IncreasesEU Poised to Impose 25 Percent Retaliatory Tariffs on U.S. GoodsChina Announces Reciprocal Tariffs on U.S. ImportsTrump’s Tariffs Generate Tons of Criticism as Uncertainty AboundsFollow us on X:Michael Smith: @TaxesMichaelDavid 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 JonesProducers: Jordan Parrish, Peyton RhodesAudio Engineers: Jordan Parrish, Peyton Rhodes

Send us a textProfessor Andrew Kahrl, author of The Black Tax: 150 Years of Theft, Exploitation, and Dispossession in America, discusses his argument that local property taxes have contributed to the disenfranchisement of Black homeowners.   Read Thorndike's book review in Tax Notes, "Is the ‘Predatory’ Property Tax an Instrument of Oppression?"Listen to more Tax Notes Talk episodes from our critical tax theory series:Addressing Tax Policy Challenges for Workers With DisabilitiesRace-Based Poll Taxes and 20th-Century DiscriminationExamining Treasury’s Review of Racial Bias in the U.S. Tax CodeFollow us on X: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.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesProducers: Jordan Parrish, Peyton RhodesAudio Engineers: Jordan Parrish, Peyton Rhodes

Send us a textKimie Eacobacci of the National Council on Disability details how a 60-year-old revenue ruling can exclude workers with disabilities from standard employment benefits and protections. Listen to more Tax Notes Talk episodes from our critical tax theory series:The Inadvertent Price of a Gender-Neutral Tax CodeRace-Based Poll Taxes and 20th-Century DiscriminationExamining Treasury’s Review of Racial Bias in the U.S. Tax CodeState Tax Authority and Native Americans: Complex and ConvolutedWealth, Inequality, and Taxes in the U.S.Taxes and the LGBTQ CommunityFollow us on X: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 JonesProducers: Jordan Parrish, Peyton RhodesAudio Engineers: Jordan Parrish, Peyton Rhodes

Benjamin Valdez, a Tax Notes IRS reporter, dives deep into the IRS's staffing woes. He discusses the drastic potential cuts of 20 to 50 percent in personnel and the chaos it could create for taxpayer services. Valdez also highlights challenges with technology modernization and privacy as employees transition back to the office. The recent leadership shake-ups, including changes at the top and the nomination of Billy Long for new IRS commissioner, add to the intrigue surrounding the agency's future.

Melissa Wiley, a Partner at Kostelanetz LLP, brings her expertise on the Corporate Transparency Act to the forefront. She discusses the Treasury's recent decision to halt penalties for domestic companies, raising important questions about regulatory gaps. Privacy concerns regarding reporting are highlighted, as individuals struggle to protect personal information. Wiley also examines the potential impacts on American taxpayers and small businesses, amidst ongoing legal challenges and the complexities of compliance in an evolving landscape.

Tony Nitti and Damien Martin from EY dive into the top tax cases of 2024, focusing on two pivotal C corporation cases, Ju et al v. United States and Stead v. Commissioner. They unravel the complexities of Qualified Small Business Stock (QSBS), discussing compliance, shareholder exclusions, and the vital role of clear documentation. The duo also explores the doctrine of constructive receipt through a tax court case, illustrating the intricacies taxpayers face with income recognition. Their engaging reflections on tax law dynamics promise to inspire proactive planning.

In this discussion, tax professionals Damien Martin and Tony Nitti from EY dive into key S corporation cases for 2024. They examine the implications of disproportionate distributions in the Maggard case, highlighting S election complexities. Insights into navigating IRS requirements for S corporations are shared, alongside challenges stemming from corporate mismanagement. The duo also emphasizes the critical role of operating agreements and documentation in maintaining tax status, ensuring viewers grasp the intricate tax landscape that S corporations navigate.

In this enlightening discussion, tax experts Damien Martin and Tony Nitti from EY dive into the significant tax cases of 2024, particularly focusing on partnerships. They dissect the Denham Capital Management LP v. Commissioner and Surk LLC v. Commissioner cases, exploring the implications for IRS interpretations and partnership roles. The conversation highlights the complex relationship between general and limited partners, their tax responsibilities, and recent legislative shifts impacting asset managers. Prepare for a blend of humor, insights, and practical tax discussions!

Joseph J. Thorndike, a Tax Notes contributing editor and historian, explores the conservative case for taxing the rich, drawing connections to President Trump’s concept of 'the forgotten man.' He examines the term's historical evolution and its reinterpretation in modern politics. Thorndike delves into the complexities of tax reform, advocating for closing loopholes and widening the tax base. He also discusses the challenges of progressive taxation amidst resistance from powerful taxpayers, highlighting the ongoing need for fair and effective tax policies.