Tax Notes Talk

Send us a textIn 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

Send us a textIn 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

Send us a textIn 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

Send us a textTax 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

Send us a textStephanie 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

Send us a textIn 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

Send us a textIn 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

Send us a textFormer 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

Send us a textU.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

Send us a textIt’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