Tax Notes Talk

Send us a textReporters highlight the quirkiest tax stories of the year.As mentioned in the episode, here is a copy of Adolf Hitler's 1926 tax return provided to Tax Analysts.For coverage of these stories in Tax Notes, see:Court Guns Down IRS Arguments Over Deductions for Cowboy GamesHitler’s 1926 Tax Return on Sale for $125,000Cirque du Soleil Founder’s Space Flight Taxable

Send us a textEmily Foster and Eric Yauch discuss some of the key elements of the recently proposed regulations on the business interest deduction limitation.For more extensive coverage, read these articles in Tax Notes:Interest Rule Leaves Securities Traders in a JamInterest Regs Muddy Partnership Debt-Equity DecisionsInterest Deduction Regs’ Antiavoidance Rule Causes ReassessmentsInterest Allocation Rules Could Wreak Havoc on GroupsInterest Regs Require Taxpayers to Decide on ‘Early Adoption’Interest Regs Raise Same Real Estate Issues as 199A RulesInterest Deduction Regs Cover More Than Just InterestInterest Regs Tackle Some Passthrough Issues, Leave Others Open

Send us a textDavid Stewart talks to Porus Kaka at the International Taxation Conference in Mumbai about various tax issues, including India's new permanent establishment concept, taxation of the digital economy, and the effects of the Tax Cuts and Jobs Act.For related coverage, read these articles in Tax Notes:India’s Tax Chief: Digital Taxation Needs Fair Allocation RulesIndia’s New PE Scheme Limited by Unanswered QuestionsIndia Seeks Input on Digital PE for Taxing Foreign CompaniesIndia's Equalization Levy Brings In Nearly $90 MillionIndia's 2018 Budget Introduces Digital PE Rules

Send us a textJad Chamseddine and Paul Jones discuss the Wayfair decision and the long-term implications for state and foreign taxes.Listen to previous episodes on Wayfair:Navigating the Post-Wayfair WorldU.S. Supreme Court Overturns QuillFor additional coverage, read these articles in Tax Notes: Texas Bill Would Provide Statewide Local Tax Rate for Remote SellersWayfair Settlement Is a Missed OpportunitySouth Dakota and Wayfair Litigants Reach SettlementCalifornia Looks to Follow South Dakota on Remote Sales Tax EnforcementAlabama Remote Sales Tax Law Could Be Model for Other StatesCalifornia Likely to Implement Wayfair in 2019Beyond Wayfair: Implications for State and Foreign Taxes

Send us a textLauren Loricchio provides an update on Amazon's choice of two HQ2 locations: Northern Virginia and the borough of Queens in New York City.For more coverage in Tax Notes, read:Louisville Won't Release HQ2 Bid, Despite Amazon Announcement Amazon's New York City HQ2 Site Eligible for Federal Tax BreaksGeorgia First Also-Ran to Reveal Incentives Offered to AmazonAmazon to Split HQ2 Between New York City, Northern VirginiaGroup Slams Reports of Two Amazon HQ2s as 'Bait and Switch'Bezos Will Let His Heart Lead Him to Amazon's New HomePittsburgh to Appeal Order Requiring Release of Amazon HQ2 Proposal

Send us a textA roundup of the November 6 midterm election results. Asha Glover and Stephen Cooper discuss what changes to look for in the new Congress, including the makeup of the House Ways and Means Committee and the tax agendas. Paul Jones and Lauren Loricchio discuss the results in the state gubernatorial races as well as the tax ballot measures approved by state voters.For more coverage in Tax Notes, see:Senators Agree on IRS Reform, Extenders as Lame-Duck PrioritiesBrady Eyes Dozens of TCJA Technical Fixes in Lame DuckWays and Means to Review Tax Extenders This WeekTax Committees Brace for Turnover in Next CongressTrump Open to Corporate Rate Increase to Get Middle-Income Tax CutNeal Wants Trump to Voluntarily Give Up ReturnsGubernatorial Winners Set to Advance Tax ProposalsVoters OK State Tax Ballot Measures on Marijuana, Income Tax CapMidterms Stifle GOP Tax Plans as Democrats Take Control in House

Send us a textJonathan Curry discusses the IRS's rules addressing strategies using trusts to sidestep the section 199A deduction limitations and claim multiple deductions.For more coverage in Tax Notes, see: 199A Regs’ Multiple Trust Rule May Invite ChallengesCreating Just One Trust for the 199A Deduction? Think AgainNon-Grantor Trusts Still Useful in TCJA PlanningIRS Drops Hammer on 199A, SALT Cap WorkaroundsIRS Likely to Trounce 199A Trust Planning Strategy

Send us a textEric Yauch discusses a provision of the Tax Cuts and Jobs Act that hasn't received a lot of attention: section 461(l), which caps excess business losses at $250,000 for individuals and $500,000 for joint filers.For more coverage in Tax Notes, see:New Loss Limitation Is on Government’s RadarNew Loss Limitation Hard to Calculate, Interpret With Other Rules

Send us a textJeremy Cape of Squire Patton Boggs discusses the tax issues arising from Brexit.For related coverage on Brexit, read these articles in Tax Notes:U.K. Tax is Lesser Concern in No-Deal BrexitU.K. Backs Customs Agents Facing Brexit Capacity ChallengeEU, U.K. Leaders Willing to Extend Brexit Transition PeriodBrexit Talks at Impasse Over Customs Backstop Proposal EU Proposes 'Least Intrusive' Customs, VAT Checks After BrexitThe U.K. Can’t Afford to Become a Tax Haven, Says Labour PoliticianEU Steps Up Complaint Against U.K. Over €3 Billion Customs FraudHMRC Warns of Customs and VAT Impact of No-Deal Brexit For more on the Jaffa Cakes and Pringles debate, see:Cake or Biscuit? Why Jaffa Cakes Excite PhilosophersThe Lord Justice Hath Ruled: Pringles Are Potato Chips

Send us a textAndrew Breiner talks to practitioners about the various issues raised by state efforts to tax peer-to-peer car rentals. For related coverage, read these articles in Tax Notes:Illinois Governor Vetoes Car Sharing Bill, Proposes Own PlanStates Look to Tax the Car-Sharing IndustryAirbnb and the Sharing Economy