Tax Notes Talk

Send us a textTax 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

Send us a textTax 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

Send us a textProfessor 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

Send us a textTax 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

Send us a textTax 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

Send us a textProfessor 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

Send us a textTax 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

Send us a textTax 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

Send us a textValerie 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

Send us a textTax 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