Tax Notes Talk

Francine J. Lipman, the William S. Boyd Professor of Law at the University of Nevada, Las Vegas, discusses her role as a Nevada state tax commissioner and her recent column in Tax Notes on U.S. Supreme Court Justice Ruth Bader Ginsburg’s pro bono tax work.***This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Tax Notes Today reporters Kristen Parillo and Jad Chamseddine discuss the Senate’s recent action on several tax treaties after a nearly decade-long delay. For additional coverage, read these articles in Tax Notes:Senate Finishes Tax Protocols, Sets Sights on Treaties NextSenate Ratifies Spain Protocol, More to ComeSenate Doesn’t Want Further Debate on Tax TreatiesTax Treaties Advance in Senate With Little BacklashTreaties Expected to Advance Despite Amendments ScareNegotiations Over Paul’s Hold on Tax Treaties Break Down

Tax Notes Today legal reporter Eric Yauch delves into the recent decisions by several private equity firms to convert to corporations in wake of the Tax Cuts and Jobs Act.For additional coverage, read these articles in Tax Notes:Carlyle’s ‘Full C Corp’ Conversion Differs From OthersPrivate Equity Firms Are Converting to Corps, Sort OfApollo Joins Fund Manager Bandwagon by Converting to C CorpC Corp Conversions Advance, Others Still Mulling Decision***This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Tax Notes Today reporters Ryan Finley and Jad Chamseddine review several European countries’ unilateral approaches to taxing the digital economy and the U.S. reaction. For additional coverage, read these articles in Tax Notes:France Confident of G-7 Digital Taxation Deal Despite U.S. ProbeFrench Senate Passes DST Despite U.S. Tariff ThreatsU.K. Proposes Draft DST Legislation Containing Double Tax ReliefLawmakers Warn of Effect of Digital Services Tax on Trade PactsTrump Orders Investigation of French Digital Services Tax***This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Jonathan 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.

Jared 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.

Steve 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

Kristen 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

Tax 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

Stephanie 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