Tax Notes Talk

Professor 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. 

Eric 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

Andrew 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.

At 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.

Tax Notes Today Legal Reporter Eric Yauch discusses the final section 199A regulations and the IRS's FAQ on the application of the new passthrough deduction.For additional coverage, read these articles in Tax Notes: IRS Sneaks ‘Nasty Surprise’ Into Expanded 199A FAQBusiness Separation Under 199A Remains a MysteryWhether a Taxpayer Qualifies for 199A Depends on Who You AskWhat Constitutes a Triple Net Lease for the 199A Safe Harbor?Rental Owners Realizing 199A Complexity as Filing Season AdvancesSeparate Business Language Tweaked in Final 199A RegsFinal 199A Rules Provide Answers to Some Structuring Questions

In a phone interview, Jonathan Curry talks to Brad Dillon of Brown Brothers Harriman about estate planning trends following the Tax Cuts and Jobs Act, as well as what keeps planners up at night ahead of the 2020 election.

Stephanie Cumings discusses the Opportunity Zone program and the highlights of the new proposed regulations.For additional coverage, read these articles in Tax Notes: O-Zone Regs May Not Totally Bar Triple Net LeasesO-Zone Regs Don’t Address Practical Tiered-Partnership IssueNew Proposed O-Zone Regs May Be the Last, Officials SayCarried Interest Benefits Curbed for Some O-Zone Investments

In part 2 of an interview with National Taxpayer Advocate Nina Olson, Tax Notes Today senior reporter William Hoffman and Olson discuss her impending retirement, her work as the national taxpayer advocate, and her future plans.

In part 1 of an interview with National Taxpayer Advocate Nina Olson, Tax Notes Today senior reporter William Hoffman and Olson discuss the filing season, the Taxpayer First Act (H.R. 1957), the disclosure of program manager technical advice, and congressional efforts to get President Trump's tax returns.For additional coverage, read these article in Tax Notes:Treasury Misses Dems’ Deadline for Handing Over Trump’s ReturnsHouse Approves IRS Reform Measure Despite Free File FightRelease of Emailed Chief Counsel Advice Dropped 17 PercentTaxpayer Advocate: IRS Using Email to Avoid Advice Disclosure

Raymond Wynman, the managing director of Global Tax Management’s International Tax practice, discusses the final rules on section 965, specifically the 965(b) basis-shifting election and the specified payment rule.