Tax Notes Talk

Jeremy Scott, Tax Analysts Chief Operating Officer, shares his expert insights into the evolving landscape of U.S. tax legislation. He discusses the limited changes anticipated in 2024 due to a divided government and how IRS funding challenges may impact operations. Scott delves into the future of the bipartisan direct file program and the expected tax policies under a potential Trump administration, highlighting significant implications for IRS scrutiny and taxpayer litigation opportunities. These insights paint a vivid picture of the complexities ahead for U.S. taxation.

Send us a textTax Notes reporters recap some of the most memorable stories they encountered in 2024, from “pig butchering” scams to a denied late-filing excuse citing Christmas stress. For additional coverage, read these articles in Tax Notes:Maine Enacts Tax Credit to Keep Portland Baseball TeamDraftKings Kills Betting Tax Surcharge ProposalDraftKings Announces Surcharge Plan on States With High Betting Taxes'Pig Butchering' Theft Losses May Evade TCJA RestrictionsMega Win for British Snack Company in VAT DisputeBritish Supermarket Owes VAT on Food Bars, U.K. Tribunal FindsNutrition Company Owes VAT on Protein Foods, U.K. Tribunal FindsListen to other tax oddities episodes:Year-End Collection: Tax Oddities of 2023Year-End Collection: Tax Oddities of 2022Year-End Collection: Tax Oddities of 2021Follow us on X:Emily Hollingsworth: @EmilyHoll9Kiarra Strocko: @KiarraStrockoDavid Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton Rhodes

Stephanie Soong, Tax Notes Chief Correspondent, dives into the latest from the OECD’s ambitious two-pillar reform project. She discusses updates on the proposed 15% minimum tax for multinationals and its implications for developing nations. The complexities of the Pillar 1 framework to streamline transfer pricing are addressed, alongside negotiations stalling over its mandatory adoption. Upcoming legal challenges in global tax reform and the fiercely debated digital services taxes are also explored, revealing a turbulent road ahead as the OECD aims for a 2025 rollout.

Tony Santiago, founder and president of TaxSearch Inc., is an authority on tax leadership and succession planning. He discusses the urgency of preparing for leadership transitions in tax departments, especially as baby boomers retire. Santiago emphasizes the need for early succession planning and internal talent development. He also highlights the evolving expectations for tax leaders, blending technical skills with strong communication. Finally, he explores the challenges and strategies of adapting to hybrid work models in tax functions.

Send us a textA Tax Notes investigation unveiled how money sheltered in offshore insurance investment vehicles has eluded IRS auditors hampered by poor training and silos within the agency.  Leaked documents obtained by the International Consortium of Investigative Journalists and reviewed by Tax Notes show private placement life insurance structures — a special type of insurance available only to wealthy investors — with millions of dollars set up in offshore tax havens like Belize and the Cayman Islands. Three members of the Tax Notes investigations team explain their reporting process, from choosing the topic to final follow-ups. If you have a tip for the investigations team, reach them at tips.investigations@taxnotes.com or through the Signal app at 347-731-3183.For more, check out the team's coverage on private placement life insurance:Chance of Changes to Life Insurance ‘Wrappers’ Dims PostelectionHow Offshore Life Insurance Helps Business Owners Minimize TaxesHigh-End Life Insurance Policies Lured Offshore by Relaxed RulesInside How Private Placement Life Insurance Slips Through the CracksTo hear Senator Wyden's full statement, visit https://www.youtube.com/watch?v=xiez_NnUBZQ.Follow us on X:Lauren Loricchio: @LaurenLoricchioChandra Wallace: @ChandraSWallaceSarah Paez: @PaezWritesKiarra Strocko: @KiarraStrockoDavid 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 textIn an exclusive sit-down interview with Tax Notes Talk, IRS Commissioner Daniel Werfel discusses his tenure and the agency’s future with major Tax Cuts and Jobs Act provisions expiring next year.For more coverage, read the following in Tax Notes:IRS Is Well Positioned to Handle Tax Bill, Werfel SaysIRS Council Calls for Public Education About Tax NoncomplianceIRS to Beef Up Artificial Intelligence Oversight StructureElection Results Cast Doubt on Fate of IRS Funding, Direct FileWerfel Says Agency Is Gearing Up to Weigh In on TCJA ExpirationFollow us on X:Ben Valdez: @benmvaldezDavid 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 textJānis Taukačs, a partner at Sorainen in Latvia, discusses the Baltic region’s tax priorities, as well as his own professional journey through the world of tax. For other episodes from Cape Town, listen to:"From Cape Town: A Sit-Down With South Africa's Top Tax Official.""From Cape Town: Developing Tax Policy for Developing Nations."For more about the Sergei Magnitsky story, read David Stewart's article in Tax Notes, "Death of Russian Lawyer Puts Spotlight on Hermitage Tax Fraud."   For more coverage, read the following in Tax Notes:OECD Framework Discussing Permanent Pillar 2 Safe HarborsFrustration Persists in OECD Framework Over Pillar 1Lithuania Tax Authority Proposes Pillar 2 Implementing RulesLatvian Parliament Passes Global Minimum Tax LegislationFollow 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 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