Tax Notes Talk

Send us a textJonathan Curry and Andrew Velarde discuss the draft regulations Tax Notes obtained from the Office of Information and Regulatory Affairs.For additional coverage, read these articles in Tax Notes:New OIRA Drafts Reveal Tweaks to TCJA GuidanceOIRA Leadership Shuffle Opens Door to Tax Reg Review Shake-UpOIRA’s Tax Reg Reviews Remain a ‘Black Box’ Despite Draft RegsSpotlight on OIRA’s Review Process Eases Politicization ConcernsOIRA’s Imprint on Tax Regs Revealed in New Cache of Documents***This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Send us a textJared Dunkin, head of tax at a Washington, D.C.-based publicly traded multinational, discusses the role practitioners have in mentoring and developing tax professionals. Dunkin is author of the book, Brass Tax: 14 Actionable Insights to Power Your Success.***This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Send us a textSteve Dixon and Kevin Kenworthy of Miller & Chevalier discuss the U.S. Supreme Court's recent decision to uphold Auer deference in Kisor v. Wilkie and what it means for the Treasury and the IRS.For additional coverage, read these articles in Tax Notes:Auer Deference Survives, But ‘Neutered’ and ‘Zombified’U.S. Supreme Court Decision on Auer Won’t Affect Tax CasesConservative Justices Question Feasibility of Auer’s SurvivalGorsuch Dissent Could Signal Beginning of the End for Chevron

Send us a textKristen Parillo and Ryan Finley discuss the Ninth Circuit's new opinion in Altera v. Commissioner upholding a regulation requiring that parties to a cost-sharing arrangement share stock-based compensation.For additional coverage, read these articles in Tax Notes:Altera, the Sequel — Jurisprudence Catches Up With BEPSAltera Decision Revives Commensurate With Income StandardNinth Circuit Again Upholds Cost-Sharing Regs in Altera

Send us a textTax Notes Today State reporter Paige Jones discusses the developments in states since the U.S. Supreme Court's June 21, 2018, decision in South Dakota v. Wayfair Inc.See the Tax Notes Nexus Tracker and these articles for more coverage:One Year Later: Experts Discuss Aftermath, Future Impact of WayfairNo New Streamlined Member States a Year After WayfairNCSL SALT Task Force Contemplates Its Future Post-WayfairRemote Sellers Seeking Relief as States Shift to Marketplace LawsNew Hampshire Wages War Against Wayfair

Send us a textStephanie Johnston discusses the G-20 finance ministers' reaction to the OECD's workplan to achieve consensus on taxing the digital economy. The G-20 finance ministers met recently in Fukuoka, Japan. For more coverage, read these articles in Tax Notes:G-20 Finance Ministers Endorse OECD Roadmap for Digital EconomyFrance Aims for G-7 Consensus to Set Stage for Digital Tax DealOECD Sets Course Toward Global Digital Tax Deal by 2020Countries Greenlight OECD Digital Tax Workplan

Send us a textProfessor Yair Listokin of Yale Law School discusses the ways that tax policy has affected past recessions and how it may help or hurt in the next one. He also takes a look at the Tax Cuts and Jobs Act from a macroeconomic tax perspective. Listokin is the author of the book, Law and Macroeconomics: Legal Remedies to Recessions. 

Send us a textEric Yauch and Andrew Velarde highlight the major themes that came up at the American Bar Association Section of Taxation meeting in Washington, including interesting insights into recent and coming regulations. For more coverage of the ABA meeting, read these articles in Tax Notes:IRS Considering More Safe Harbors in O-Zone RulesPartnerships Can Defer Section 1231 Gain Under O-Zone RulesTreasury Carefully Considering Interest Definition in Final RulesTriple Net Lease Changes Likely in Final 199A Safe HarborIRS Won’t Be as Forgiving of TCJA Comment DeadlinesWilkins Predicts Temporary Regs Will Disappear From RulemakingTreasury, IRS Open to Suggestions on PTI SimplificationU.S. Officials Urging Delay of DSTs as Negotiations ContinueLooming Tax Court Trial Will Test Economic Substance DoctrineBridging the Guidance Enforcement Gap Is IRS Priority

Send us a textAndrew Velarde talks to Joe Calianno of BDO about the pending final guidance on the global intangible low-taxed income provision enacted as part of the Tax Cuts and Jobs Act, and Paige Jones talks to Scott Smith of BDO about the state responses to GILTI.

Send us a textAt a breakfast panel of the American Bar Association Tax Section meeting in Washington, David Stewart talks to Lilian Faulhaber and Will Morris about the taxation of the digital economy. Lilian Faulhaber is a professor at Georgetown Law, and Will Morris is the deputy global tax policy leader at PwC.