Tax Notes Talk

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

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

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

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

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

Send us a textProfessors Edward Fox and Zachary Liscow discuss their proposal for a new tax on billionaires that would apply to borrowing against their assets. For more, read Fox and Liscow's article, "No More Tax-Free Lunch for Billionaires: Closing the Borrowing Loophole," in Tax Notes.For more on wealth taxes, listen to The Wealth Tax Debate.Follow us on Twitter:Robert Goulder: @RobertGoulderDavid 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

Send us a textTax Notes Capitol Hill reporters Cady Stanton and Doug Sword discuss the key provisions of the Tax Relief for American Families and Workers Act and its potential paths for passage in the Senate. For additional coverage, read these articles in Tax Notes:House Kills SALT Marriage Penalty Bill in Procedural VoteSmith Combats Claims Senate Republicans Weren’t in Tax TalksSenate Border Traffic Jam Pushes Tax Bill Back Weeks, at LeastHouse Tax Deal Vote Hasn’t Swayed Senators Seeking MarkupFollow 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.For more information on Ask Blue J, visit bluej.com/ask. ***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Send us a textProfessor Roberta Mann of the University of Oregon School of Law explains how taxing single-use plastics could help combat their environmental effects.  For more, read Mann's article, "Targeting Plastic Pollution with Taxes."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.This episode is sponsored by TaxBandits. For more information, visit taxbandits.com and use promo code TaxNotes5.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Send us a textTax Notes managing legal reporter Andrew Velarde discusses the economic substance doctrine dispute in Liberty Global Inc. v. United States and its potential implications. For previous Moore episodes, listen to the following:A Recap of SCOTUS Oral Arguments in Moore v. United StatesMoore Money, More Tax Problems? Analyzing Moore v. United StatesFor additional coverage, read these articles in Tax Notes:ABA Section of Taxation Meeting: Liberty Global Is a Warning Against High-Level Business PurposeLiberty Global Appeals Economic Substance Loss to Tenth CircuitLiberty Global Promises Economic Substance Doctrine AppealEconomic Substance Doctrine Constrains Liberty GlobalFollow 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.This episode is sponsored by TaxBandits. For more information, visit taxbandits.com and use promo code TaxNotes5.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Send us a textKelly Phillips Erb, known online as Taxgirl, discusses the 2024 filing season’s challenges and considerations in light of the IRS’s post-IRA funding changes and the potential for congressional action on a tax deal. For additional coverage, read these articles in Tax Notes:IRS Hasn’t Been Idle During ERC MoratoriumIRS Launches Direct-File PlatformHopes for Senate Markup of Tax Deal Complicated by TimingIRS Unveils Sleeker Notices Ahead of Filing SeasonTax Deal Puts a Damper on Filing Season OptimismWerfel: Shutdown During Filing Season Could Be ‘Very Disruptive’Filing Season Tax Changes Could Be Challenging for Direct FileFollow us on Twitter:Jonathan Curry: @jtcurry005David 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 TaxBandits. For more information, visit taxbandits.com and use promo code TaxNotes5.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart