Tax Notes Talk

Former 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

U.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

It’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

Dan Neidle of Tax Policy Associates in London discusses the United Kingdom’s recent mini-budget and what effects the new tax proposals may have. For additional coverage, read these articles in Tax Notes:Cutting Taxes Is ‘the Right Thing to Do,’ Truss SaysKwarteng Forced Into ‘Screeching U-Turn’ on Income Tax RatesKwarteng to Bring Forward Medium-Term Fiscal PlanKwarteng Criticized Over Delayed Publication of OBR ForecastU.K. Treasury Stands Firm Amid Criticism of Tax Measures In our “Editors’ Corner” segment, Karl Frieden, vice president and general counsel of the Council On State Taxation, chats about his coauthored Tax Notes piece, “Down the Rabbit Hole: Sales Taxation of Digital Business Inputs.” We 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 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

Eric Solomon of Steptoe & Johnson LLP discusses the new excise tax on corporate stock buybacks and examines the issues that the IRS and Treasury will need to tackle before its implementation.Listen to our other episodes on the tax-related provisions in the Inflation Reduction Act:U.S. Tax Provisions Driving the Fight Against Climate Change$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:IRS Officials Turn Attention and Increased Resources to IRA Lawmakers Indefinite on SPAC Buyback Tax ReliefNew Trouble Ahead for SPACs: The Stock Buyback TaxBuyback Tax May Alter Equity Compensation and Retirement PlansWe want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.Follow us on Twitter:Chandra Wallace: @ChandraSWallaceDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by SafeSend. For more information, visit safesend.com.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

Tax 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

Lauren 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

Robert 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

Caroline 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

Professor 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