Talking Tax

The union that represents about 65,000 IRS employees is teaming up with the agency to help attract new talent amid a hiring spree.The Democrats' tax-and-climate law gave the IRS tens of billions to dollars to modernize and go after taxpayers who haven't been paying what they owe. To do that, the IRS needs to build up its workforce, but it is competing with the more-lucrative private sector. That's where the National Treasury Employees Union is stepping in.Bloomberg Tax reporter Erin Slowey spoke with NTEU National President Doreen Greenwald about what the union is doing to negotiate benefits and flexibilities that make it more attractive to come work at the IRS, and why it's important to have a fully funded agency. She also warned about what a possible shutdown in early 2024 would do to the current and prospective workforce.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

More of the supply chain that helps create semiconductor chips wants in on a lucrative new tax credit aimed at boosting US competitiveness against China.As of now under IRS proposed rules, companies that manufacture materials or chemicals supplied to the manufacturing of semiconductors or equipment don't qualify for the 25% tax credit from the 2022 CHIPS Act.Bloomberg Tax’s Erin Slowey speaks with Tymon Daniels, vice president of tax for Corning Inc., a US materials science company that is the parent company of Hemlock Semiconductor, about the congressional intent of who should be able to qualify and the importance of have the direct pay option— where the industry can get cash in lieu of the tax credit.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

African countries face several challenges in negotiating the global tax deal involving more than 140 countries at the Organization for Economic Cooperation and Development.The agreement includes reallocation of the residual profits of large multinational companies to market jurisdictions, known as Pillar One, and a 15% global minimum tax, known as Pillar Two.On this week’s episode of Talking Tax, Bloomberg Tax senior reporter Danish Mehboob speaks with Logan Wort, executive secretary at the African Tax Administration Forum, about why developing countries feel they don't have a seat at the table for these negotiations and why some would prefer to have the project play out at the United Nations rather than the OECD.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Marita Sciarrotta, the new acting director of New Jersey's Division of Taxation, will have a busy year ahead as she settles into the role.Sciarrotta, who spent 40 years in the tax division before taking over as acting director in September, said in an interview that she wants to modernize the state's property tax relief programs—an endeavor that likely will require legislation to make needed changes. She also plans to increase hiring as state revenue agencies across the nation grapple with a growing number of vacancies that can impede their abilities to provide financial oversight.On this episode of Talking Tax, reporter Danielle Muoio Dunn spoke with Sciarrotta about her plans as the division takes on lawmakers’ overhaul of New Jersey’s corporate tax system and the creation of StayNJ, a property tax relief program for seniors. Sciarrotta also discussed her long tenure in the division and the sexism she's faced over the years."There are some people that kind of tend to be siloed off and one of the things I found to be most advantageous in my career is that I get like a morbid curiosity and I will ask about anything to anyone and stick my nose in a lot of different places," Sciarrotta said.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

(Note: This episode originally aired June 1, 2023)What does it mean to be a good tax leader, as an in-house tax professional or as a tax adviser who wants to make the tax functions of your clients better? How do you build a great team?Bloomberg Tax Insights editor Rebecca Baker sat down with Jared Dunkin, the vice president of tax and senior tax counsel at FTI Consulting, and Dunkin’s mentor and former boss, Todd Davis, the executive vice president and senior tax counsel for Warner Bros. Discovery, to find some answers to these questions.Dunkin and Davis discuss how to handle the ambiguity of tax when corporate executives—their bosses—demand certainty, how to wage the war for talent, and how to set priorities for their tax teams, particularly when it comes to cross-border tax work.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

For more than a year, a group of wealth management advisers met regularly to devise strategies to defend their wealthy clients' keeping their riches in individual retirement arrangements based in Malta.The pension plans—which emerged out of a loophole in a 2011 tax treaty between the US and the Mediterranean island nation widely seen as a tax haven—involved a cottage industry of advisers, accountants, and attorneys to facilitate transactions that allowed cash, business interests, and several types of income to go untaxed.The plans were added to IRS's "Dirty Dozen" list of dubious tax schemes in July 2021. But participants in the participants' monthly Zoom meetings felt "the IRS was too simple, too lazy, or too stupid to figure out what we were doing," according to one wealth adviser who attended them. That changed in June, when the IRS served hundreds of criminal summonses on taxpayers and Malta pension plan promoters. While no charges have been filed yet, IRS Commissioner Danny Werfel has been vocal about cracking down on abusive tax schemes, especially now that his agency is infused with billions in new funding from last year's tax-and-climate law.In this week's episode of Talking Tax, host David Schultz talks to Bloomberg Tax reporter Michael J. Bologna about his story digging into the wealth advisers' meetings, how these Malta plans were marketed to high-net-worth individuals, and what's next for the IRS investigation.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The clock is ticking on Gov. Kathy Hochul (D) to take action on legislation that would make New York the first state to publicly list the owners behind limited liability companies.The bill, A3484A, would require LLCs to disclose their beneficial owners and other identifying information, such as their business street address. Those who fail to comply for more than two years would be shown as “delinquent” on state records and subject to a $250 penalty. Entities with “significant privacy interests” could apply for a waiver to not appear in the state registry.On this episode of Talking Tax, Bloomberg Tax spoke with state Sen. Brad Hoylman-Sigal, the Manhattan Democrat who sponsored the bill, and Chelsea Lemon, director of government affairs for the Business Council of New York, which opposes the legislation."The LLC Transparency Act doesn't minimize or alter the legal structure or protections of LLCs, but it provides necessary transparency for the public's benefit, as well as our law enforcement," Hoylman-Sigal said.Other proponents, including state Attorney General Letitia James and Comptroller Thomas DiNapoli, have said the opaque structure of LLCs allow corrupt actors to hide their financial dealings and contribute to issues like tax evasion and money laundering. Opponents, such as real estate groups, have raised privacy concerns with it and said it will hurt the state's economic competitiveness.A spokesperson for Hochul said she's "reviewing the legislation." She has until Dec. 31 to act on the bill. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

A Supreme Court case challenging the constitutionality of the mandatory repatriation tax provision could have broad implications on the tax code. The potential outcome could result in refunds to multinational companies and disrupt other taxes on foreign income. The arguments in the case focus on the distinct nature of the mandatory repatriation tax and whether it can be struck down without affecting the rest of the tax code. The podcast also explores the impact on partnership taxation, LLCs, and mark to market regimes, as well as the potential consequences on revenue, litigation, and tax policy.

Sam Bankman-Fried, accused of federal fraud charges for siphoning customer funds from FTX, and Donald Trump, accused by NY AG of inflating real estate values, are discussed in this podcast. The role of accountants in these trials and their evolving responsibilities in fraud cases are explored, including the challenges in hiring expert witnesses. The decline of accountants and the challenges faced in the profession, such as increased SEC enforcement and decreased accounting graduates, are also addressed.

Legislation and proposed regulations on cryptocurrency have the potential to answer some open questions about the taxation of digital assets, though not all of the possible changes may be welcomed by industry.A bill from Sens. Cynthia Lummis (R-Wyo.) and Kirsten Gillibrand (D-N.Y.) touches on a variety of crypto tax issues. It would provide a narrow definition of broker for tax reporting, require the marking of crypto assets to market for year-end accounting purposes, and closea tax loophole that may upset some in the industry. The Senate Finance Committee also asked for more information on those crypto taxation issues earlier this fall.On this episode of Talking Tax, Lisa Zarlenga, the head of Steptoe & Johnson LLPs tax policy practice and a former tax legislative counsel at the Treasury Department, spoke to Bloomberg Tax about that legislation and new proposed regulations on tax reporting rules for crypto brokers.Closing a tax loophole that allows investors to claim losses by quickly selling and repurchasing their digital assets, for example, may be difficult to implement as some investors would trigger the rule unintentionally, she said.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.