Tax Notes Talk

Jonathan Curry takes a fresh look at the tax regulatory review agreement between the Office of Management and Budget and Treasury now that the process has had time to play out.For further coverage, read these articles in Tax Notes:OIRA Review of Tax Regs Presses on Despite ShutdownA Look Ahead: Treasury, OIRA to Chart New Territory as Final Regs Flood InTreasury, OIRA Still at Odds Over When Tax Regs Merit ReviewTax Regs Deemed Significant Skyrocket Under New Agenda

Jeremy Scott, Stephanie Cumings, and Andrew Velarde provide a review of what happened with tax legislation and guidance in 2018 and what's ahead in 2019.For additional coverage, read these articles in Tax Notes:Neal Planning for TCJA Hearing by January’s EndA Look Ahead: Legislators Queuing Up Multiple Retirement BillsA Look Ahead: Healthcare Tax Policy Could Stem From Divided CongressHouse Passes GOP Tax Bill With No Hope for EnactmentA Look Ahead: Awaiting Clarification of 199A and Audit Regime RulesA Look Ahead: Questions Abound on Exec Comp Grandfathering RuleA Look Ahead: 2019 Should See Final Bonus and Tax Accounting Regs

In the second volume, reporters highlight the quirkiest tax stories of the year.For coverage of these stories in Tax Notes, see:Meals Deduction Guidance Comes Off the Back BurnerNew Business Meals Guidance Creates Substantiation ConcernsCalifornia Pot Money Takes Long, Strange Trip to BankHistoric $5.6 Million Washington State Tax Zapper Case Dismissed Cheesecake Factory Asks for Cherry on Top

Reporters 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

Emily 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

David 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

Jad 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

Lauren 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

A 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

Jonathan 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