Tax Notes Talk

Send us a textProfessor Afton Titus of the University of Cape Town explains her view on how the tax initiatives of the OECD and United Nations affect developing nations. For other episodes from Cape Town, listen to "From Cape Town: A Sit-Down With South Africa's Top Tax Official." For more coverage, read the following in Tax Notes:Trump Win Casts Shadow Over OECD Global Tax ReformsOECD Framework Discussing Permanent Pillar 2 Safe HarborsFrustration Persists in OECD Framework Over Pillar 1U.N. Official Floats Cooperation With OECD on Tax Dispute IssuesNew U.N. Model Tax Treaty Article Is a Win for Developing CountriesBilateral Treaty Sourcing Rules Harm Developing Countries, Paper SaysFor information about our live Taxing Issues event, visit: https://events.taxanalysts.org/tawebinar112024 Follow us on X:David Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Send us a textSouth African Revenue Service Commissioner Edward Kieswetter discusses his tenure leading the agency and the country’s position in the modernization of the international tax system.For more coverage, read the following in Tax Notes:DSTs Could Violate Tax Treaty Obligations, U.N. Official SaysEU Commission Fully Supports Permanent Pillar 2 Safe HarborOECD Framework Discussing Permanent Pillar 2 Safe HarborsFrustration Persists in OECD Framework Over Pillar 1U.N. Official Floats Cooperation With OECD on Tax Dispute IssuesNew U.N. Model Tax Treaty Article Is a Win for Developing CountriesSouth African Tax Chief Warns Taxing Right Fight Will IntensifyFor information about our live Taxing Issues event, visit: https://events.taxanalysts.org/tawebinar112024 Follow us on X:David Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Send us a textTax Notes contributing editor Robert Goulder shares his take on the effects of the Foreign Account Tax Compliance Act and common reporting standards on the feasibility of taxing foreign assets.Listen to our previous episodes on taxing hidden assets:The Constitutionality of Penalties on Undeclared AssetsAmerica the Tax Haven? Exploring the U.S. Trade DeficitFor more coverage, read the following in Tax Notes:Trump Vows to End ‘Double Taxation’ of Overseas CitizensCourt Tells DOJ No Do-Over in Venture Capitalist FBAR CaseEU, Belgium Say Domestic Bank Secrecy Hinders Tax TransparencyU.S., Switzerland to Exchange Info Under New FATCA Deal From 2027IRS Approves Argentina’s Data Security for FATCA ExchangesTransparency Not a Threat to Privacy, Tax Justice Network SaysFor information about our live Taxing Issues event, visit: https://events.taxanalysts.org/tawebinar112024 Follow us on X:Bob Goulder: @RobertGoulderDavid Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Send us a textMonisha Santamaria and Nick Tricarichi of KPMG discuss the scope of the latest guidance on the corporate alternative minimum tax and its impact on tax and accounting professionals.Listen to our previous episode on CAMT: Navigating New Guidance on the Corporate Alternative Minimum TaxFor more coverage, read the following in Tax Notes:Exempt Orgs Get Temporary Break From Filing Corporate AMT FormCorrections Coming for Corporate AMT Proposed RegsTreasury Downplays FTC Timing Concerns in Corporate AMT RegsMore Corporate AMT Safe Harbors Are on the TableAnalysis: CAMTyland Adventures, Part V: Coping With CAMTyland GriefFor information about our live Taxing Issues event, visit: https://events.taxanalysts.org/tawebinar112024 Follow us on X:Chandra Wallace: @ChandraSWallaceDavid Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Send us a textTax Notes White House reporter Alexander Rifaat discusses the tax policies proposed by Vice President Kamala Harris and former President Trump. For more coverage, read the following in Tax Notes:Trump Proposes Tax Write-Off for Generator PurchasesTrump Proffers Tax Incentives for Car Owners, ManufacturersTrump’s Plan Would Swell Deficit More Than Harris’s, Study SaysNo Indication Vance Will Release Tax ReturnsHarris Proposes New Manufacturing Tax CreditUnrealized Capital Gains Proposal Faces Uncertain PathHarris Says ‘Trump Tax’ Would Cost Americans $4,000 AnnuallyHarris Held Talks With Union Before Making Tip PledgeAudio clips obtained from C-SPAN.Follow us on X:Alexander Rifaat: @AlexRifaatDavid Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Send us a textTax Notes contributing editor Robert Goulder discusses the history of foreign bank account reporting penalties and how two recent court cases could affect the FBAR regime. For more coverage, read the following in Tax Notes:Jury Finds Professor’s FBAR Failures WillfulFBAR Penalty Circuit Split Has Potential for Supreme Court ReviewSchwarzbaum FBAR Penalty Dispute Results in Circuit SplitCourt Tells DOJ No Do-Over in Venture Capitalist FBAR CaseNinth Circuit Approves Prejudgment Interest for FBAR PenaltiesFollow us on X:Bob Goulder: @RobertGoulderDavid Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Send us a textProfessors Kenneth Austin and Hillel Nadler discuss the policies that they believe make the United States a tax haven, and the resulting effects on the economy.For more, read Nadler and Austin's article in Tax Notes, "America the Tax Haven and Its Trade Deficits."Listen to more Tax Notes Talk episodes about tax havens:Bad Credit: A Look at Switzerland’s Bank SecrecyLet’s Talk Tax Havens: The EU Blacklist and the Pandora PapersFor more coverage, read the following in Tax Notes:EU to Remove Antigua and Barbuda From Tax BlacklistResearchers Try to Quantify Firms’ Use of Tax Havens After TCJABEPS Activity May Have Declined in Tax Havens, OECD ReportsMontana DOR Amends Code to Remove Tax Haven LanguageThe EU Tax Blacklist: A Six-Year Journey Toward ComplianceFollow us on X:David Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Send us a textTax Notes contributing editor Nana Ama Sarfo discusses methane-related tax policy and how it might lead to future taxation of greenhouse gas emissions. For more on taxing greenhouse gases, listen to Is Carbon Pricing the Best Way to Mitigate Climate Change?For additional coverage, read Sarfo's analysis in Tax Notes: The Future of Carbon Taxes Could Lie in MethaneFollow us on X:Nana Ama Sarfo: @nanaama_sarfoDavid Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Ryan Finley, a contributing editor known for his expertise in tax law, joins the conversation to dissect the EU Court of Justice's ruling on Ireland's €13 billion unlawful state aid to Apple. He delves into the complexities of the Advance Pricing Agreements that have fueled ongoing judicial appeals. The discussion also navigates the broader implications of the ruling for future state aid enforcement across EU countries and how it might influence tax strategies for multinational corporations.

Send us a textAlan McLean, chair of the tax committee at Business at OECD, discusses the developments in the international business tax world during his tenure and the committee’s priorities. Listen to our episode with Will Morris, former chair of the tax committee, here: The Tax Diplomat: Reflections From Former BIAC Tax ChairFor more coverage, read the following in Tax Notes:OECD Targets Country Benefits That May Weaken Pillar 2 RulesBusinesses Call for Central Platform for Global Minimum Tax DataGLOBE Permanent Safe Harbor Idea May Boost EU CompetitivenessFollow us on Twitter:Stephanie Soong: @StephanieSoongDavid Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart