Tax Notes Talk

Send us a textTax Notes contributing editor Ryan Finley discusses the latest updates in recent transfer pricing cases Eaton and Medtronic II. Listen to related episodes:Transfer Pricing Litigation UpdateCoca-Cola Transfer Pricing Challenge FizzlesFor additional coverage, read these articles in Tax Notes:Analysis: Medtronic and the Role of Unspecified Transfer Pricing MethodsMedtronic Might Trigger Up to $2 Billion Tax LiabilitySixth Circuit Sides With Eaton in APA Cancellation AppealMedtronic II’s Unspecified Method Raises Specific QuestionsIn our “Editors’ Corner” segment, Fernanda Kotzias, a counselor at the Brazilian Administrative Tax and Customs Court of Appeal, chats about her coauthored Tax Notes piece, “Brazil-U.S. Trade Agreement: A New Chapter for Trade Facilitation.” We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.Follow us on Twitter:Ryan Finley: @ryanmfinleyDavid 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 textLauren Collins of Vinson & Elkins LLP provides an overview of the new tax credits designed to reduce greenhouse gas emissions in the Inflation Reduction Act. Listen to our other episodes on the tax-related provisions in the Inflation Reduction Act:$80 Billion in New Funding: What’s Next for the IRS?Analyzing the Corporate Alternative Minimum TaxFor additional coverage, read these articles in Tax Notes:U.S. Is Lagging on Social Cost of Carbon, Study SaysLawmakers Seek Assistance for Clean Energy and EV Tax CreditsYellen to Promote New Tax Measures With Speaking TourFollow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Avalara. For more information, visit avalara.com/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 textRobert Kerr of Kerr Consulting LLC discusses how the $80 billion of additional funding for the IRS in the Inflation Reduction Act could be best used by the agency. For additional coverage, read these articles in Tax Notes:Backlog Thwarted IRS’s ‘Well-Planned’ IT Modernization StrategyIRS Urged to Budget for TransparencyYellen to Promote New Tax Measures With Speaking TourTax Professionals See Little to Fear in IRS Hiring BlitzCBO: IRS Funding Won’t Generate Much From Taxpayers Under $400KIn our “Editors’ Corner” segment, Sarah-Jane Morin, a partner with Morgan, Lewis & Bockius LLP, chats about her coauthored Tax Notes piece, “How the Definition of Digital Asset Brokers Was Brokered.” We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.Follow us on Twitter:Jonathan Curry: @jtcurry005David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Avalara. For more information, visit avalara.com/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 textCaroline Rule of Kostelanetz & Fink LLP discusses the post-Roe tax complications for employers covering abortion-related interstate travel expenses. For more, read Rule's article, "Tax Implications of Dobbs for Interstate Travel Expenses to Obtain Abortions," in Tax Notes.We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.Follow us on Twitter:Caitlin Mullaney: @MullaneyWritesDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Avalara. For more information, visit avalara.com/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 textProfessor Jeremy Bearer-Friend of the George Washington University Law School highlights key areas of the IRS’s tax enforcement where racial bias can occur. For more, read Bearer-Friend's article, "Colorblind Tax Enforcement."We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.Listen to more Tax Notes Talk episodes from our critical tax theory series: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:Nana Ama Sarfo: @nanaama_sarfoDavid 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 textReuven Avi-Yonah of the University of Michigan Law School discusses the new corporate alternative minimum tax and how it intersects with international taxation. For additional coverage, read these articles in Tax Notes:Inflation Reduction Act Raises Pillar 2 Hopes and ConcernsHard Part Begins for IRS and Treasury as Biden Signs Reconciliation BillCritics Recall BURP in Debate Over Corporate Minimum TaxWe want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.Follow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Avalara. For more information, visit avalara.com/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 textKyle Pomerleau of the American Enterprise Institute discusses the key tax provisions of the Inflation Reduction Act and what they mean for the future of tax policy. For additional coverage, read these articles in Tax Notes:House Democrats Tee Up Tax Bill Debate and Nix GOP AmendmentsCritics Recall BURP in Debate Over Corporate Minimum Tax Democrats Play Whack-a-Mole as GOP Rages Against IRS Funding Partnership Rules Likely at Root of Corporate Minimum Tax FightBiden and Democrats Relish Passage of Reconciliation BillWe want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.Follow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by SafeSend. For more information, visit safesend.com.For more information and to download the Tax Advisory Industry Report, visit taxnotes.co/report.For more information about the Tax Analysts Public Service Fellowship, visit our press release at taxnotes.com/fellowship.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Send us a textTax Notes reporter Benjamin Guggenheim discusses the latest tax legislation on Capitol Hill: the recently passed CHIPS and Science Act and the revived reconciliation bill known as the Inflation Reduction Act. For additional coverage, read these articles in Tax Notes:Sinema Wants Carried Interest Out of Reconciliation, Reports SayClawbacks Will Prevent Companies From Exporting CHIPS BenefitsEx-Treasury Secretaries Support Inflation Reduction ActDemocrats Hit Back at Criticism of Inflation Reduction ActReconciliation Tax Reform Limited by Delicate NegotiationsComputer Chip Bill Passes House, Heads for Biden SignatureKey Senators Reach Deal on Corporate Tax, Carried InterestIn our “Editors’ Corner” segment, John Craig, an associate in the Washington office of Gibson, Dunn & Crutcher LLP, chats about his coauthored Tax Notes piece, “The Appeals Access Saga Continues.” We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.Follow us on Twitter:Benjamin Guggenheim: @ben_guggenheimDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by SafeSend. For more information, visit safesend.com.For more information about the Tax Analysts Public Service Fellowship, visit our press release at taxnotes.com/fellowship.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Send us a textMartin A. Sullivan, Tax Analysts’ chief economist, revisits the United States’ economic path to inflation and discusses mitigation efforts for a possible recession. For more inflation coverage on the podcast, listen to Inflation, Tax, and the COVID-19 Economy.For additional coverage, read these articles in Tax Notes:Grassley Follows Up With Second Inflation-Indexing PackageNorth Carolina Republicans' Budget Preserves Income Tax CutsCalifornia Budget Deal Includes Billions in Inflation ReliefWe want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.Follow us on Twitter:Martin Sullivan: @M_SullivanTaxDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by SafeSend. For more information, visit safesend.com.For more information and to download the Tax Advisory Industry Report, visit taxnotes.co/report.***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 Johnston recaps the agreement on the OECD’s two-pillar corporate tax reform plan and discusses recent roadblocks to full implementation.Listen to more podcast episodes on the OECD's tax reform plan:The End Is Nigh: An Update on the OECD Tax Reform PlanThe Beginning of the End? An Update on the OECD Tax Reform PlanNew Year, New Tax Rules? An OECD Tax Reform Project UpdateFor additional coverage, read these articles in Tax Notes:U.K. Moves to Implement OECD-Brokered Global Minimum Tax RulesG-20 Ministers Push Ahead on Global Tax Reform Amid U.S. HurdlesWhite House Downplays Global Tax Deal ConcernsIndia Calls for Syncing Pillar 2 Treaty Rule and Amount B RulesOECD Fills in More Blanks on Amount A Draft Model Tax RulesTreasury to Nix Tax Treaty With Hungary for EU Minimum Tax VetoSupport Rises for Circumventing Hungary on Pillar 2Hungarian Lawmakers Nix EU Pillar 2 Minimum Tax DirectiveIn our “In the Pages” segment, Heydon Wardell-Burrus, a researcher at the Oxford Centre for Business Taxation, chats about his Tax Notes piece, “Can Pillar 2 Be Leveraged to Save Pillar 1?”We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.Follow us on Twitter:Stephanie Soong Johnston: @SoongJohnstonDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by SafeSend. For more information, visit safesend.com.For more information about the Tax Analysts Public Service Fellowship, visit our press release at taxnotes.com/fellowship.***CreditsHost: David D. StewartExecutive Producers: