Talking Tax

Brazilian taxpayers and practitioners continue to clamor for more guidance on the country's new transfer pricing regime implemented last year.The country switched from a mathematical model to an arm's-length principle for transfer pricing last year, bringing it in line with global standards.That pivot left a lot of questions for the Receita Federal, the country’s revenue authority, to answer through guidance, and it's been working to issue rules ever since. Most recently, Brazil issued instructions requiring extensive reporting and documentation of transactions involving commodities and how companies calculate their transfer pricing positions.Transfer pricing involves valuation of transactions between entities within a corporate group. Intragroup transactions must be conducted at arm’s length—priced similarly to transactions between unrelated companies.The country’s auditors are gearing up to enforce Brazil's new rules, sparking some concerns among practitioners that many new auditors will be learning on the job and that these early examinations won’t go smoothly.RSM US senior tax manager Nina Baumbach spoke with reporter Caleb Harshberger about the changes and what they mean for companies. She said companies need more guidance and clarity from the government on intangibles and other topics.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Treasury Department and IRS finalized rules requiring crypto exchanges to provide information on taxpayers’ buying and selling activities are meeting industry and Republican pushback.Centralized brokers must issue form 1099-DA, starting in 2026 for tax year 2025, and decentralized brokers are to start doing so in 2028 for tax year 2027. The form includes such things as personal data, gross proceeds on sales, and transaction dates.Crypto tax advisers bring up two themes about the new rules: First, it's challenging for some brokers to implement the infrastructure needed to comply with the reporting requirements because tracking transactions is a huge undertaking when trades happen so quickly. Second, some Congressional Republicans don't like the rule and have introduced a joint resolution to nullify parts of the regulations.In this episode of Talking Tax, Bloomberg Tax reporter Rebecca Chen chats with Jessalyn Dean, vice president of tax information reporting at digital asset tax and accounting platform Ledgible, on the requirements and enforcement efforts, and how they might change under the second Trump administration.—Produced by Mo Barrow.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

President Donald Trump threw a major wrench into the fate of the OECD global tax deal on his first day in office, sparking concerns among the international tax community about the deal being fundamentally reshaped.Trump issued a presidential memo Jan. 20 stating the global tax deal has no "force or effect" in the US and instructed the Treasury Department to come up with a list of protective measures to impose on any country that enacts discriminatory or extraterritorial taxes against American taxpayers.This week, Bloomberg Tax reporter Lauren Vella sits down with Scott Levine, Treasury's former deputy assistant secretary for international affairs and top US OECD tax delegate, to chat about the status of the global deal and the impact of the new US administration's position on negotiations.Levine maps out two scenarios he sees playing out in Paris under the new Trump administration and gives some insight into how countries at the OECD might be feeling about the transition of power in the US.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Few of the provisions of the tax code this year have garnered as much attention from industry as the about-to-sunset pass-through deduction.In their 2017 tax overhaul, Republicans allowed owners of pass-through businesses such as partnerships, S-corporations, and LLCs to deduct 20% of certain business income from their taxes. Businesses and their lobbyists say it gives those firms small and large parity with traditional corporations. Critics say its benefits largely flow to the wealthy.That deduction—along with the rest of the individual provisions of that 2017 law known as the Tax Cuts and Jobs Act—expires at the end of 2025 absent congressional action and President Donald Trump's signature.On this episode of Talking Tax, Bloomberg Tax reporter Zach Cohen spoke with two guests about what the deduction does and prospects for renewal by Congress this year. Jeff Brabant is a vice president of federal government relations at the National Federation of Independent Businesss, and Elena Spatoulas Patel is a nonresident senior fellow at the Urban-Brookings Tax Policy Center and the Sorenson Assistant Professor in the Division of Quantitative Analysis of Markets and Organizations at the University of Utah’s David Eccles School of Business.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The leader of a top US standard-setter wants his board to take the next step in using emerging technology to craft accounting rules for local and state governments.Joel Black, chair of the Governmental Accounting Standards Board, said a key priority for the board this year is shifting gears from monitoring emerging tools such as artificial intelligence to preparing for its future integration. In his final two years as leader, Black said he intends to craft an enduring focus on how technology can make financial reporting more efficient.GASB establishes standards for state and local governments that follow generally accepted accounting principles, or GAAP. Cities and states' staffing shortages and resource constraints have motivated the board to be especially selective about the projects it takes on, Black said.The board is currently working to update how governments should value infrastructure assets such as bridges and tunnels, as well as develop digital classifications for financial reporting.Black, who previously worked at Mauldin & Jenkins LLC and KPMG LLP, has led the board since 2020.Bloomberg Tax reporter Jorja Siemons spoke with Black about his 2025 priorities.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

President-elect Donald Trump's plans to deconstruct the federal workforce would take a bite out of IRS efforts to answer taxpayer phone calls and enforce compliance for tax cheats.After getting billions in funding from the 2022 tax-and-climate law, the IRS started a long-needed rebuild, including bringing on more workers. Between Oct. 1, 2021 and Sept. 30, 2023, the IRS processed nearly 53,000 new hires, the Treasury Inspector General for Tax Administration said in a September report.But Trump's promises to end remote work for federal workers and reinstate a policy that would make it easier to fire certain employees are seen as ways to end the IRS's competitiveness in the job market and ability to keep employees who are flight risks.Bloomberg Tax reporter Erin Slowey spoke with Kelly Reyes, executive director of the Professional Managers Association that represents the interests of IRS managers, about what a presidential transition means for IRS employees and how agency managers are preparing for next tax filing season.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Jan. 3 marks the beginning of the next Congress, where Republicans will lead both chambers and control the White House.Democrats being out of power has big implications for tax policy, as GOP lawmakers heading into the new year debate what to renew from the 2017 GOP tax law, known as the Tax Cuts and Jobs Act.The TCJA was passed with no votes from Democrats and benefits skewed toward the wealthy and corporations. Incoming GOP leaders have proposed breaking their top priorities into two bills and moving them through Congress using the reconciliation process.The first would jump-start President-elect Donald Trump's priorities on immigration and gas drilling, and the second would include tax and other legislative priorities.Republicans say moving tax legislation to later in the year would give them more time to decide what to do about many of the law’s individual provisions that expire at the end of 2025. They also will have to decide what Trump campaign promises to include.On this episode of Talking Tax, Bloomberg Tax reporters Chris Cioffi, Zach Cohen, and Lauren Vella discuss what to expect in the 2025 tax fight, and the policy issues that likely will define the debate.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Online retailers that rely solely on third-party logistics providers like Amazon for tax compliance may still face tax liability for direct sales through their own websites.Many states enacted marketplace facilitator laws in the years since the Supreme Court's 2018 ruling in South Dakota v. Wayfair, shifting tax collection responsibilities to platforms like Amazon or Walmart. But individual vendors can still face additional tax obligations because of direct sales, how their inventory is controlled, or state-specific sales thresholds.As of October, most of the 24 states in the Streamlined Sales and Use Tax Agreement, which aims to simplify sales tax codes, said inventory in a third-party warehouse creates a physical nexus—a connection that triggers tax responsibilities. Rules vary even more outside the Streamlined pact. In New York, for instance, storage alone is sufficient for nexus, while in Arizona, inventory beyond a seller’s control likely doesn't.Bloomberg Tax reporter Angélica Serrano-Román and Diane L. Yetter, founder of the Sales Tax Institute, discussed how businesses using third-party logistics services navigate tax compliance, the inconsistency in court decisions on who is liable for tax collection and remittance, and the contentious issue of retroactivity where states might seek uncollected taxes from before the Wayfair decision.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690

A new White House administration and Republican-led Congress are slated to disrupt how the IRS operates.Republicans' taste for cuts to the agency's annual appropriations and the tens of billions of added funding from the 2022 tax-and-climate law is putting the IRS and the Treasury Department on offense, as they make a case for why a well-funded IRS is good for everyone.The Treasury Department has warned that further clawbacks would mean customer service—a bipartisan concern—as well as enforcement efforts, would take a hit.Bloomberg Tax's Erin Slowey spoke with Charles Rettig, a shareholder at Chamberlain Hrdlicka, on why the IRS needs its funding and how a new commissioner could shake up the agency. Rettig, who served as commissioner during the first Trump administration, also addressed what he is telling his clients amid the uncertainty.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Fuel producers are trying to prepare for a tax credit regime change, even though the Treasury Department has failed to issue rules around those credits.The clean fuel production tax credit under Section 45Z takes effect next year, replacing a longstanding blenders credit. The new credit gives tax breaks to fuel according to its carbon intensity score. But the yet-to-be-released Treasury and IRS rules will explain how to calculate that score.Debbie Gordon, leader of RSM US LLP's excise and energy tax practice, told reporter Erin Schilling on this week's episode of Talking Tax podcast that fuel producers are still trying to prepare for the new credit, even amid that uncertainty. It's unclear when the clean fuel production tax credit rules will come out, though a Treasury spokesperson said the Biden administration expects to put out some guidance before the administration change in January.Many also are trying to push to start construction on clean fuel projects before the end of this year to qualify for the current credits. Gordon gives insight on what fuel producers are doing to safeguard their projects, how they're preparing for the new credit, and what the new administration means for the future of the credit.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690