Talking Tax

The OECD just published the parameters of a deal that would exempt US companies from two key enforcement rules in the global minimum tax framework. The deal, which spans 88 pages in the form of administrative guidance, includes a slew of safe harbor rules that address everything from how US companies can get the exemption to more advantageous treatment of substance-based tax incentives like the US R&D credit. It includes a permanent, simplified global minimum tax calculation. Other countries would be able to obtain carve-outs like the ones obtained by the US and its multinational companies—if they meet certain criteria. This week on Talking Tax, reporters Lauren Vella and Somesh Jha discuss why the deal and the timing of its release is important, what it means for multinational businesses, how key US lawmakers reacted, and what the deal means for the efficacy of the global minimum tax going forward. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

We're off for the New Year holiday, so we're serving up an encore presentation of a Talking Tax podcast about challenges with paying student athletes. Ever since student athletes gained the right to be compensated for use of their image in advertisements and merchandise sales, the money has flooded in, but so have some problems. The athletes can now be compensated for their name, image, and likeness—or NIL—but schools still can’t directly pay them for playing. Instead, athletes can receive compensation when merchandise with their name or number is sold, or for showing up in advertisements or social media posts for businesses. But the line between legitimate NIL and illegitimate pay-for-play can get blurry. On this episode of Talking Tax, University of Kentucky professor Stephen Lusch talks with reporter Caleb Harshberger about how transfer pricing and tax law concepts can show whether the deals are done at reasonable prices that really reflect the value the student brings. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

PwC's new training program aims to give early-career recruits hands-on experience integrating artificial intelligence tools into everyday work. The Big Four accounting and advisory firm started piloting AI immersion sessions in October, with a full rollout to new US associates slated for July. The sessions are happening across PwC's tax, assurance, and advisory business. "We truly believe that the role of the new associate will be changing with AI and that their role will become somewhat elevated, and we need to make sure that we're really training them on those skills to work and think differently," said Margaret Burke, the firmwide talent acquisition and development leader for PwC US. Like its competitors, PwC has recently funneled resources into next generation autonomous tools aimed at handling routine tasks solo. The firm said in November it shed about 150 jobs across marketing, human resources, and other US support roles as part of a longer-term effort modernizing its back-office unit, including through using new AI tools. In this week's Talking Tax, Burke and PwC US Tax Leader Krishnan Chandrasekhar sat down with Bloomberg Tax reporter Jorja Siemons to discuss how the AI trainings have gone so far and what skills they hope new employees learn. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

A slew of big tax disputes and the worldwide upheaval brought on by the Trump administration's aggressive trade policy made for an exceptionally interesting year for transfer pricing professionals, and left them with lingering questions heading into 2026. President Donald Trump's April tariff announcements sent shock waves through the global economy and forced corporate tax heads—and C suites—to start figuring out what it all meant for their tax and transfer pricing positions, and whether they needed to make changes to fend off potential audits. At the same time, companies are seeing a growing number of audits and transfer pricing disputes—often with big dollar figures—as tax authorities around the world beef up their auditing and enforcement capabilities with staff, AI, and stronger reporting requirements. Auditing multinationals can bring them big tax rewards. That might be less true at the IRS, where the Trump administration has drastically reduced resources and staffing. On this episode of Talking Tax, Bloomberg Tax transfer pricing reporter Caleb Harshberger discusses what's been going on in the world of transfer pricing—which governs transactions within corporate groups—and what he's keeping an eye out for next year. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Carolyn Schenck, a former IRS attorney with two decades of experience in tax evasion, shares her insights on tax fraud enforcement in a time of reduced IRS resources. She warns that there's no federal statute of limitations for fraud, making any gamble on weakened enforcement risky. Schenck discusses how staffing cuts could embolden tax cheats but emphasizes the potential for increased IRS efforts, especially in digital assets like crypto. She also highlights the need for better resources and technology to combat illegal tax shelters.

Anna Dolganoff, a Roman historian from the Austrian Academy of Sciences specializing in ancient legal documents, joins journalist Caleb Harshberger for a riveting discussion on a rediscovered Roman papyrus detailing a tax-fraud case. They explore the intricacies of a cross-border tax evasion scheme involving enslaved individuals, the harsh realities of Roman court practices, and the severe penalties faced by the accused. Anna highlights how this ancient case sheds light on the long-standing issues of tax fraud, revealing that it’s a problem as old as civilization itself.

Join Zach C. Cohen, a Bloomberg Tax reporter who analyzes IRS operations and funding, alongside Erin Durkin, a Bloomberg Government health reporter focusing on healthcare subsidies. They discuss the impact of the recent government shutdown on the IRS, highlighting staffing uncertainties and substantial backlogs. Erin sheds light on the fate of pandemic-era premium tax credits, predicting a spike in average premiums if not extended. With potential legislative hurdles ahead, they unpack the chances of another shutdown looming around these critical subsidies.

Jeremy Gove, a state and local tax attorney at Eversheds Sutherland, shares insights on the tax implications of New York City Mayor-elect Zohran Mamdani's ambitious affordability agenda. He discusses the calls and emails from anxious clients after the election. Gove emphasizes the legal hurdles the mayor faces in raising taxes, cautions against hasty decisions for high-net-worth individuals contemplating relocation, and mentions the potential benefits of increased audit staff to address the Department of Finance's backlog.

Ron Messenger, CEO of Grant Thornton's audit business, shares insights on navigating the firm’s shift to a private equity-backed structure. He discusses the innovative two-part legal framework designed to protect audit integrity while leveraging investment. The conversation highlights the crucial services agreement that outlines governance and resource sharing. Ron emphasizes the importance of maintaining high audit quality amidst profit pressures and the role of regulators in safeguarding independence. His advice to firms considering outside capital focuses on collaboration and strategic planning.

Steve Soter, vice president at Workiva and expert in financial compliance, discusses the implications of potentially shifting from quarterly to semiannual 10-Q filings. He warns that this change could undermine AI models that analysts rely on for accurate reporting. Soter explains the benefits of XBRL structured data for machine readability and the risks associated with relying on unstructured text. He advises C-suite leaders on proactive measures to maintain data integrity and ensure transparency, emphasizing the critical need for more frequent, accurate reporting.