Tax Notes Talk

Tax Notes managing legal reporter Caitlin Mullaney explores the Supreme Court’s oral arguments in V.O.S. Selections and Learning Resources and predicts whether the Court will strike down President Trump’s tariffs. For related tax news, read the following in Tax Notes:Michigan Agencies Forecast Tariff Impacts on Prices, JobsSupreme Court Justices Question Trump's IEEPA TariffsTrump-Xi Summit Yields Lower Tariffs All Around**This episode is sponsored by Avalara. For more information, visit avalara.com.***CreditsHost: David D. StewartExecutive Producers: Jeanne Rauch-Zender, Paige JonesProducers: Jordan Parrish, Peyton RhodesAudio Engineers: Jordan Parrish, Peyton Rhodes****Nominate someone for the Tax Analysts Award of Distinction in U.S. Federal Taxation! For more information, visit awards.taxanalysts.org.

Carolyn Schenck, former IRS national fraud counsel, shares insights from decades at the agency, including her pioneering role and her recent move to private practice. For related tax news, read the following in Tax Notes:Fresh Look at Exempt Orgs Could Be Good, Former CI Employee SaysMove to Direct IRS CI at Left-Leaning Groups Is Questioned‘Tax Enforcement Is Not Dead,’ Departing IRS Fraud Counsel Says**This episode is sponsored by Avalara. For more information, visit avalara.com.***CreditsHost: David D. StewartExecutive Producers: Jeanne Rauch-Zender, Paige JonesProducers: Jordan Parrish, Peyton RhodesAudio Engineers: Jordan Parrish, Peyton Rhodes****Nominate someone for the Tax Analysts Award of Distinction in U.S. Federal Taxation! For more information, visit awards.taxanalysts.org.

Elisângela Rita, a former member of the U.N. Committee of Experts on International Cooperation in Tax Matters, discusses her career in international tax and the evolution of U.N. global tax convention discussions. For more episodes from Lisbon, listen to:From Lisbon: Portuguese Tax Administration in the Digital AgeFrom Lisbon: Highlights From the 2025 IFA CongressFor related tax news, read the following in Tax Notes:U.N. Trudges Forward on Framework ConventionU.N. Tax Committee to Tackle Transfer Pricing, AI, Tax NexusEU Commission's U.N. Tax Mandate Faces Countries' PushbackFollow us on X:Sarah Paez: @PaezWritesDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Avalara. For more information, visit avalara.com.***CreditsHost: David D. StewartExecutive Producers: Jeanne Rauch-Zender, Paige JonesProducers: Jordan Parrish, Peyton RhodesAudio Engineers: Jordan Parrish, Peyton Rhodes****Nominate someone for the Tax Analysts Award of Distinction in U.S. Federal Taxation! For more information, visit awards.taxanalysts.org.

Helena Alves Borges, the General Director of the Portuguese Tax and Customs Authority, reveals insights on modernizing tax administration. She discusses the agency's digital transformation and the importance of skilled recruitment. The conversation covers international cooperation and adapting to Pillar 2 complexities, stressing consensus at EU and OECD levels. Helena highlights the use of AI for efficiency while ensuring data security, and reflects on her role in promoting gender diversity in leadership. A forward-looking vision emphasizes a shift to data-driven processes in tax administration.

Tax Notes contributing editor Robert Goulder discusses the upcoming oral arguments before the Supreme Court on the validity of the Trump administration's recent reciprocal tariffs and speculates on the Court's reaction.For more tax news and analysis, read the following in Tax Notes:Nonprofits Urge SCOTUS to Side With Trump Admin in Tariff DisputePresident Can Impose Tariffs Under IEEPA, Admin Tells SCOTUSANALYSIS: V.O.S. Selections, Part 2: Will SCOTUS Rescue Trump's Tariffs?ANALYSIS: V.O.S. Selections, Part 1: Are Trump's Tariffs 'Too Big to Fail'?Supreme Court Will Hear Trump's Appeal of Tariff RulingsFollow us on X:Robert Goulder: @RobertGoulderDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Avalara. For more information, visit avalara.com.Join us at the inaugural Tax Trends Summit in Washington, D.C. presented by Tax Notes and the ABA Tax Section. For more information, visit taxnotes.co/taxtrends25.***CreditsHost: David D. StewartExecutive Producers: Jeanne Rauch-Zender, Paige JonesProducers: Jordan Parrish, Peyton RhodesAudio Engineers: Jordan Parrish, Peyton Rhodes

Tax Notes reporter Sarah Paez breaks down the biggest international tax developments from the annual Congress of the International Fiscal Association in Lisbon, Portugal.For more coverage, read the following in Tax Notes:OECD Plans 2026 Draft on Transfer Pricing Guidelines RevisionsEU Wants Its U.S. Subsidiaries to Be Subject to Top-Up TaxESG Ratings Don’t Inform Tax Risk, HMRC Official SaysPillar 2 Permanent Safe Harbor Talks Focused on Integrity IssuesFollow us on X:Sarah Paez: @PaezWritesDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Avalara. For more information, visit avalara.com.Join us at the inaugural Tax Trends Summit in Washington, D.C. presented by Tax Notes and the ABA Tax Section. For more information, visit taxnotes.co/taxtrends25.***CreditsHost: David D. StewartExecutive Producers: Jeanne Rauch-Zender, Paige JonesProducers: Jordan Parrish, Peyton RhodesAudio Engineers: Jordan Parrish, Peyton Rhodes

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