Talking Tax

About three months have passed since Treasury Secretary Scott Bessent announced that the US, along with its Group of Seven allies, agreed to work on a system that would exempt American companies from parts of the global minimum tax. In that time, the US proposed a technical solution to separate its tax system from the global minimum tax. But other countries have raised concerns about what the US position means for their own tax sovereignty and whether their companies will be left at a competitive disadvantage compared to their American counterparts. In this episode of Talking Tax, Bloomberg Tax reporters Saim Saeed and Lauren Vella hash out these countries' frustrations and discuss the feasibility of coming to an agreement on a "side-by-side" system by Dec. 31, the deadline suggested by the Trump administration. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Michael Rapoport, a senior reporter at Bloomberg Tax, dives into the significant exodus of IRS and DOJ attorneys since 2017. He reveals how this staffing crisis could stretch tax litigation timelines and force the IRS into less favorable settlements. Rapoport explores how job frustrations and uncertain hiring prospects are driving this trend, shedding light on its impact on high-profile cases and taxpayer interactions. His insights provide a crucial understanding of the shifting landscape in tax disputes.

President Donald Trump's widespread tariffs are boosting tax dispute risks for companies that are scrambling to understand how to factor the new trade duties into their transfer pricing and tax planning without attracting an audit. Tariffs raise the prices of imported goods, meaning companies importing products from their own affiliates may have to—or want to—adjust the pricing of those transactions to meet transfer pricing rules that require them to treat the deals as though they were done at arm's length, with unrelated parties. The added cost of the tariff will likely knock the pricing for many goods out of that arm's-length range, so companies may have to adjust these prices to stay compliant. Additionally, companies may be able to make adjustments to mitigate the tariff impacts by reducing the price the US entity pays for the good. These adjustments can attract scrutiny, however, from both tax and customs agencies. And growing geopolitical tensions may make it hard for companies to rely on tax dispute resolution mechanisms like mutual agreement procedures. In this episode of the Talking Tax Podcast, Crowe LLP transfer pricing practice leader Sowmya Varadharajan talked with reporter Caleb Harshberger about the choices, and risks, companies are facing. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Jennifer MacMillan, President of the National Association of Enrolled Agents, shares insights on the challenges tax preparers face with a reduced IRS workforce. She discusses the crucial need for clearer IRS guidance on new tax laws and payroll estimations. With the potential for scams and confusion around tax filing, MacMillan emphasizes the importance of regulating tax preparers to protect consumers. The conversation highlights the urgency of adapting to policy changes while ensuring taxpayer rights are maintained in an evolving landscape.

As the funding deadline looms, Congress faces an uphill battle to agree on IRS funding and tax breaks. The podcast dives into the potential chaos of a government shutdown, highlighting the IRS's urgent challenges without a permanent commissioner. It also tackles the intricacies of bipartisan support in the Senate and the implications for future tax policy. The tension between parties could complicate significant budget reconciliations, leaving lawmakers scrambling to make crucial decisions amidst partisan divides.

Glen Marku, a principal at Grant Thornton, shares critical insights into how tariffs impact multinational companies' intangible assets, like intellectual property. He discusses the staggering growth of these assets, which now represent 90% of the S&P 500's value. Marku explains how tariffs can indirectly raise product prices and emphasizes the importance of strategic IP management to minimize tax burdens. He also examines the risks and opportunities of relocating manufacturing in light of shifting tax regulations, urging businesses to adapt their strategies accordingly.

KPMG is at the forefront of adopting AI, aiming to seamlessly blend technology with employee development. Sandy Torchia discusses how they are training workers to thrive in an automated environment while preserving company culture. Interns anticipate significant automation in their roles, prompting strategic shifts in talent attraction amid a competitive landscape. The firm also emphasizes the importance of hybrid work dynamics and internal mobility, ensuring employees grow alongside technological advancements and client demands.

In this engaging discussion, Roman historian Anna Dolganov from the Austrian Academy of Sciences reveals intriguing insights from a recently translated scroll detailing ancient tax evasion tactics. She uncovers a sophisticated scheme involving forgery and manipulation of slave ownership aimed at dodging taxes in Roman provinces. The conversation highlights the parallels between historical and modern evasion methods and the severe punishments faced by tax evaders in that era. Dolganov also shares the ongoing research ambitions that could shed more light on this fascinating topic.

Pharmaceutical companies are facing a storm as they adapt to looming tariffs and the complexities of transfer pricing. The discussion highlights how these tariffs could revolutionize where drugs are manufactured and where intellectual property resides. Companies are exploring varied strategies to navigate the shifting landscape, while concerns about drug pricing and national security arise. The podcast concludes with insights into the future implications of these trade policies and their potential impact on the pharmaceutical industry.

Erin Slowey, a Bloomberg Tax reporter specializing in IRS leadership changes, dives deep into the chaos at the IRS following the departure of former Commissioner Billy Long. She discusses the implications of high turnover, with seven leaders since 2025, and how this instability affects taxpayer trust. Slowey highlights the challenges facing new nominees, particularly in terms of qualifications and public scrutiny. The conversation also touches on the impact of political uncertainty and the crucial Senate confirmation process for a new IRS leader.