
Tax Notes Talk
A discussion of cutting-edge developments in tax, including up-to-the-minute changes in federal, state, and international tax law and regulations.
Latest episodes

May 3, 2024 • 24min
ERC Updates: Handling the Flood of Improper Claims
Send us a textMary Wood of Meadows Collier discusses recent updates on the employee retention credit, from the IRS’s moratorium on new claims to the potential effect of pending legislation. For more episodes on the employee retention credit, listen to:IRS Key Updates: ERC, EITC, and Government Shutdown PlansThe Employee Retention Credit: Scams and SuccessesFor additional coverage, read these articles in Tax Notes:Pandemic Relief Fraud Scheme Shut Down, TIGTA SaysIRS Leaves Door Open to Resume ERC Voluntary DisclosureERC Voluntary Disclosure Program Barrels Toward Uncertain EndERC Abuse Revives Debate Over Contingency FeesIRS ERC Audits Undergo Changes as They Get OlderFollow us on Twitter:Lauren Loricchio: @LaurenLoricchioDavid Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Apr 26, 2024 • 43min
Going to the Source: A New Approach to Personal Income Taxation
Send us a textProfessor Yariv Brauner of the University of Florida Levin College of Law discusses the challenges facing residence-based taxation and his proposal for a new way to tax individuals. For more, read Brauner's article, "Taxing People, Not Residents."In our “Editors’ Corner” segment, Andrey Yushkov, senior policy analyst for the Tax Foundation, chats about his coauthored Tax Notes piece, “Long-Term Trends in State Personal Income Tax.” Follow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by PLI Press. For more information, visit pli.edu/taxnotes.Join the Tax Notes Talk team for our upcoming live recording at the ABA May Tax Meeting on Friday, May 3! Fore more information, visit taxnotes.co/aba.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Apr 19, 2024 • 28min
What the End of Chevron Deference May Mean for Tax
Send us a textFrank Agostino of Agostino & Associates discusses two pending Supreme Court cases, their potential effects on the Chevron doctrine, and their implications for the tax world.Listen to our latest episode on Moore here: A Recap of SCOTUS Oral Arguments in Moore v. United States For additional coverage, read these articles in Tax Notes: Late Chevron Challenge to Split-Dollar Regs Falls FlatStates Are Moving Away From Judicial Deference, Practitioners SayPetitioner Asks SCOTUS to Hold Case Until Chevron Is DecidedA Look Ahead: Penalty Approval Issues Likely Won’t Be Solved Through RegsFollow us on Twitter:MK Browne: @mk_browne10David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by PLI Press. For more information, visit pli.edu/taxnotes.Join the Tax Notes Talk team for our upcoming live recording at the ABA May Tax Meeting on Friday, May 3! Fore more information, visit taxnotes.co/aba. ***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Apr 12, 2024 • 25min
Growing Deficit and the Future of U.S. Fiscal Policy
Tax Analysts' chief economist Martin Sullivan discusses the impact of the Tax Cuts and Jobs Act, the Congressional Budget Office's projections on tax policy, and the challenges of U.S. fiscal policy. Topics include regressive effects of tax cuts, strategies to address the deficit, and upcoming tax analysis in Tax Notes magazines.

Apr 5, 2024 • 16min
The SEC’s Final Climate Disclosure Rules: Simpler but Disputed
Send us a textTax Notes contributing editor Nana Ama Sarfo discusses the SEC’s recently released carbon pricing disclosure rules and their reception from the business community. For additional coverage, read Sarfo's article in Tax Notes, "Examining the SEC’s Simpler Carbon Pricing Disclosure Rules."Follow us on Twitter:Nana Ama Sarfo: @nanaama_sarfoDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.This episode is sponsored by PLI Press. For more information, visit pli.edu/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Mar 29, 2024 • 33min
What’s a U.S. Trade or Business? Analyzing YA Global
Send us a textWilliam McRae of Cleary Gottlieb discusses the U.S. Tax Court’s decision in YA Global Investments v. Commissioner and what it means for the private equity sector. For additional coverage, read these articles in Tax Notes:Tax Pro Questions Tax Court’s Dealer Analysis in YA GlobalTax Pros Weigh Impact of YA Global on Fund IndustryYA Global Footnote Shouldn’t Be OverlookedCayman Islands Hedge Fund Liable for Tax Bill of Over $57 MillionFollow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Mar 22, 2024 • 17min
Senate Stasis: An Update on Congress’s Tax Deal
Send us a textTax Notes Capitol Hill reporters Cady Stanton and Doug Sword discuss the roadblocks the Tax Relief for American Families and Workers Act is facing in the Senate.For additional coverage, read these articles in Tax Notes:Crapo’s Tax Deal Offers Were Non-starters for Dems, Wyden SaysFinance Republicans Have Problem With Tax Bill’s Retroactivity Wyden Warns It’s Now or Never for R&D and Other Biz Tax BreaksLarger Priorities and Slow Discussions Leave Tax Bill in LimboTax Deal Doesn’t Have Support to Skirt Filibuster, Crapo SaysFollow us on Twitter:Cady Stanton: @cady_stantonDoug Sword: @doug_swordDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Mar 15, 2024 • 15min
An Update on Pillar 1 Amount B
Send us a textTax Notes chief correspondent Stephanie Soong discusses the latest developments surrounding amount B under pillar 1 of the OECD’s two-pillar corporate tax reform plan. Listen to our last podcast on amount B: Pillar 1 Amount B: Disagreements and DividesFor additional coverage, read these articles in Tax Notes:Amount B Transfer Pricing Approach Doesn’t Deliver, BIAC SaysAmount B Might Have a Phase 2, Bello SaysAmount B Won’t Change Australia’s Inbound Distributor ApproachNew Zealand Won’t Adopt Amount B Transfer Pricing FrameworkOECD Sets Out Amount B Transfer Pricing Simplification FrameworkAmount B Tax Certainty Is a Red Line for U.S., Bello SaysFollow us on Twitter:Stephanie Soong: @StephanieSoongDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Mar 8, 2024 • 26min
Navigating the Corporate Transparency Act
Send us a textChristine Green of Steptoe & Johnson PLLC discusses the Corporate Transparency Act and the recent litigation regarding its constitutionality. For additional coverage, read these articles in Tax Notes:U.S. Court Declares Corporate Transparency Act UnconstitutionalYellen: New Beneficial Ownership Reporting Rules Already WorkingFinCEN Finalizes Access Rule for Beneficial Ownership ReportingIRS Criminal Investigators Won’t Enforce New Transparency RulesFinCEN Finalizes Reporting Extension Rule Without More ReliefFollow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Mar 1, 2024 • 39min
Medtronic, 3M, Abbott Labs, Oh My! Transfer Pricing Update
Send us a textTax Notes contributing editor Ryan Finley discusses the latest developments in three transfer pricing cases — Medtronic, 3M, and Abbott Labs — and their implications for the future. For additional coverage, read these articles in Tax Notes:Business Groups Urge Eighth Circuit to Overturn Tax Court in 3MMedtronic Budges on CUT Method in Round 2 at Eighth CircuitAbbott Labs Revives Fight Over Stock Options in Transfer PricingBlocked Brazilian Income Can’t Be Taxed in U.S., 3M Brief Argues3M Challenges Blocked Income Regs at Eighth CircuitGovernment Resumes Defense of Its Transfer Pricing for MedtronicCoca-Cola’s Brazilian Income Not Blocked, U.S. Tax Court SaysIn our “Editors’ Corner” segment, Edith Brashares, former director in the Treasury Office of Tax Analysis, chats about her coauthored Tax Notes piece, “Is the Economic Analysis Section of Regs Worth the Trouble?” Follow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart
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