Talking Tax

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.

Beth Bell, a former Treasury official with extensive experience in multilateral tax negotiations, now serves as a principal at PwC's National Tax Service. In this discussion, she reveals the Treasury's efforts to implement GOP tax law despite the government shutdown. Bell analyzes the timeline for the U.S. Pillar Two coexistence and cautions companies to adhere to current rules until final legislation emerges. She also addresses the potential reintroduction of Section 899 and what factors might influence congressional actions on tax policy.

Ryan Hogg, a Bloomberg Tax reporter specializing in Irish fiscal policy, dives into the complexities of Ireland's tax landscape. He discusses the challenge of maintaining competitiveness amid Donald Trump's tax policies and the looming 15% global minimum tax. Hogg explores the government's plan to increase the R&D tax credit and the creation of a sovereign wealth fund to stabilize against future shocks. He also highlights the reliance on foreign multinationals, which pay a staggering 88% of the corporation tax, raising concerns about fiscal sustainability.

Pete Sepp, President of the National Taxpayers Union, shares insights on the recent appointment of Frank Bisignano as IRS CEO. He expresses concerns over the vacancy of top IRS positions and the need for a permanent commissioner. Sepp delves into governance questions related to the new CEO role and the plight of the dormant oversight board. He highlights potential privacy risks from merging the IRS and Social Security leadership and stresses the importance of robust data security measures. Sepp advocates for legislative clarity in IRS operations.