Tax Notes Talk

Rajat Bansal, a departing member of the U.N. Committee on Experts on International Cooperation in Tax Matters, recaps the group’s milestones over the last four years and describes what challenges lie ahead.For additional coverage, read these articles in Tax Notes:The Evolution of the U.N. Tax Model — Software Payments as RoyaltiesU.N. Tax Committee Notes Support for Revising Royalty DefinitionU.N. Releases New Transfer Pricing Manual for Developing CountriesU.N. Tax Committee Greenlights Carbon Taxation HandbookU.N. Committee Approves Digital Services Tax Treaty Article TextProposed U.N. Model Treaty Article on DST on Track for 2021 ***CreditsHost: David D. StewartExecutive Producers: Jasper B. SmithShowrunner: Paige JonesAudio Engineer: Jordan ParrishGuest Relations: Christa Goad

Joseph Bishop-Henchman of the National Taxpayers Union Foundation discusses the litigation of a provision in the American Rescue Plan Act restricting states from using federal funds provided by the law to offset reductions in net tax revenue. For additional coverage, read these articles in Tax Notes:Civil Liberties Group Sides With Ohio in Offset Provision LawsuitOhio Attorney General Seeks Permanent Injunction in Tax Restriction SuitOffset Provision Guidance Could Be Thorny for States Eyeing Tax CutsJudge Denies Ohio's Request to Prevent Treasury From Enforcing Offset ProvisionJudge Dismisses Missouri's Suit Over Restriction on Federal FundingFederal Government Argues 13 States Lack Standing for Preliminary ReliefTreasury Issues Much-Awaited Guidance on Tax Offset Provision In our “In the Pages” segment, University of Virginia School of Law professor Ruth Mason chats about her recent Tax Notes piece, “State Aid Enforcement After Amazon.” ***CreditsHost: David D. StewartExecutive Producers: Jasper B. SmithShowrunner: Paige JonesAudio Engineer: Jordan ParrishGuest Relations: Christa Goad

Professor Patricia A. Cain of the Santa Clara University School of Law discusses the unique tax challenges faced by members of the LGBTQ community in the past and today. ***CreditsHost: David D. StewartExecutive Producers: Jasper B. SmithShowrunner: Paige JonesAudio Engineer: Jordan ParrishGuest Relations: Christa Goad

Kevin Brown, an associate with Morrison & Foerster LLP, discusses his proposal for taxing moon-based activity. Read Brown's piece in Tax Notes, "Tax the Moon That the Earth May Prosper: How to Tax Lunar Occupation."In our “In the Pages” segment, Steven N.J. Wlodychak, the former indirect state and local tax policy leader for EY, discusses his recent Tax Notes piece, “Why Aren’t U.S. States Subject to International Tax Treaties?” ***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Janelle JulienShowrunner: Paige JonesAudio Engineer: Jordan ParrishGuest Relations: Christa Goad

Tax Notes legal reporter Jennifer McLoughlin and contributing editor Kristen Parillo discuss two important tax cases heard by the Supreme Court: Americans for Prosperity Foundation and CIC Services.  For additional coverage, read these articles in Tax Notes:Limitations of CIC Services Opinion Are UnclearLawsuit on Access to Appeals Barred Under CIC Services, DOJ SaysSupreme Court’s CIC Services Opinion Clarifies Scope of AIAProfessor Highlights Potential Reach of California Donor Disclosure CaseCalifornia Donor Disclosure Law Is Chilling, Attorney Tells SCOTUSU.S. Lawmakers Seek Justice Barrett’s Recusal in Donor Disclosure Case**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producer: Jasper B. SmithShowrunner: Paige JonesAudio Engineer: Jordan ParrishGuest Relations: Christa Goad

Tax Notes legal reporters Ryan Finley and Kiarra M. Strocko discuss the EU General Court’s judgments in Amazon and Engie and their effect on state aid rules.  For additional coverage, read these articles in Tax Notes:Amazon May Force the EU Commission to Change Its ApproachAmazon and Engie Cast Doubt on State Aid Enforcement ApproachEngie Loses €120 Million Tax Fight Against European CommissionLuxembourg Gets Resounding Win in Amazon State Aid DecisionAmazon Must Repay €250 Million in Unpaid Taxes to Luxembourg, European Commission SaysIn our “In the Pages” segment, Alan D. Viard, a resident scholar at the American Enterprise Institute, discusses his upcoming Tax Notes piece, “Notches in the Tax System: the Good, the Bad, and the Ugly.” **This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producer: Jasper B. SmithShowrunner: Paige JonesAudio Engineer: Jordan ParrishGuest Relations: Christa Goad

Tax Notes contributing editor Robert Goulder discusses the Biden administration’s approach to the OECD’s two-pillar solution to taxing the digital economy and the potential for global consensus. For additional coverage, read Goulder's piece in Tax Notes:Treasury’s Pillar 1 Reset: In Praise of Comprehensive ScopingAll Roads Lead to Ireland: Pillar 2 and the Path of Least ResistanceThe BEPS Gambit: Will the OECD Know When to Resign?**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Janelle JulienShowrunner: Paige JonesAudio Engineer: Jordan ParrishGuest Relations: Christa Goad

 Jonathan Curry of Tax Notes recaps the tax provisions of President Biden’s American Families Plan and discusses with Dean Zerbe of Alliantgroup the finer details and its likelihood of passing Congress. For additional coverage, read these articles in Tax Notes:Yellen Leaves Door Open to Deficit-Financing Biden’s Big PlansBiden’s NII Tax Fix Destined to Be the Bane of PractitionersRepublicans Denounce Biden’s Tax Hike ProposalsLike-Kind Exchange Proposal Is a Job Killer, Say ProsDemocrats See Room for Improvement in Some Biden Tax ProposalsBiden’s Next Plan Targets Like-Kind Exchanges, Stepped-Up BasisBiden Tax Gap Plans Prompt Business, Taxpayer Rights ConcernsBiden Sets Date to Unveil Tax Proposals Aimed at the RichCharlotte Tolman of Stibbe discusses her new Tax Notes column, “In Step With Stibbe.” Check out our episode on the first package of President's Biden Build Back Better plan, "The Biden and Wyden Tax Plans."**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Janelle JulienShowrunner: Paige JonesAudio Engineer: Jordan ParrishGuest Relations: Christa Goad

Enrolled agents Eva Rosenberg and Jeffrey Schneider share their experiences on communicating with the IRS during the coronavirus pandemic and how the agency can improve.  For additional coverage, read these articles in Tax Notes:IRS Remote Employees Mull Telework Despite Processing BacklogsIRS Backlogs to Last at Least Until Summer, Taxpayer Advocate SaysFound Money and Powerlessness: Tax Pros Share 2021 Ups and DownsReturn Filing Extension Receives Widespread ApprovalIRS Data Analytics Pros Still See Need for Human TouchIRS Exec Pushes for Agency ‘Digitalization’ Funding**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Janelle JulienShowrunner: Paige JonesAudio Engineer: Jordan ParrishGuest Relations: Christa Goad

David Thompson of the National Council of Nonprofits talks about how tax policy affects tax-exempt organizations and tax issues on the nonprofit industry’s radar today.  For additional coverage, read these articles in Tax Notes:IRS Official Outlines Status of EO ExaminationsIRS Clarifies Reporting of Emergency Grants to College StudentsLawmakers Reintroduce Legislation to Expand Charitable DeductionIRS Tackling Coronavirus Guidance for EOsNonprofits Seek Enhanced Giving Deduction for Non-ItemizersBrian Hamer of the Multistate Tax Commission discusses his recent Tax Notes piece “An Insider’s View of the MTC’s P.L. 86-272 Project.” **This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Janelle JulienShowrunner: Paige JonesAudio Engineer: Jordan ParrishGuest Relations: Christa Goad