Talking Tax

Tax data and technology can be helpful for companies when making projections for tax planning purposes, but companies have to weigh when the best time is to implement them.Data can give more certainty for companies in scenario planning, such as for the Inflation Reduction Act and everyday business decisions, said Greg Engel, vice chair of tax at KPMG LLP. Still, 52% of companies aren’t using tax data for this work, according to a recent KPMG report.On this episode of Talking Tax, Engel speaks about the importance of companies incorporating tax data into tax planning, how companies are trying to hire to fill this need, and why now is the best time to integrate it.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The IRS is seeking to prevent new, potentially abusive transactions from gaining traction with taxpayers. Early this year, the agency launched a group, called the Joint Strategic Emerging Issues Team, so that representatives from a wide range of IRS offices can collaborate to quickly identify areas where there's a high risk of noncompliance and determine how best to address these issues.On this episode of Talking Tax, we speak with two IRS officials involved in the team: Benjamin Swartz, senior adviser to the commissioner of the Small Business/Self-Employed Division, and Holly Porter, associate chief counsel for passthroughs and special industries.Swartz and Porter discuss the goals of JSEIT, the makeup of the team, and the types of issues the group is focusing on.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Tax directors around the world are grappling with a two-pillar global tax agreement that will require multinational companies to change where and how much tax they pay.As details of how these complex new rules will work in practice come to light, some companies have begun modeling their effect on their tax bills.Rio Tinto PLC, which is part of the OECD's business advisory group, has had a front row seat during the development of the rules and has already put together a team to analyze their impact.On this episode of Talking Tax, we speak with Mark Munsel, general manager of the OECD digital project at Rio Tinto. He heads up the multi-disciplinary team at the company that has been tasked with figuring out how the rules work.Munsel advises companies to start early and begin collecting and organizing the data required to comply with the rules, or risk not being ready when countries start implementing them.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The accounting world has been shaken up with several high-profile mergers and acquisitions among firms in recent years, reflecting the growing needs of clients.Abe Schlisselfeld of Marks Paneth LLP had a front-row seat to this trend, serving as the firm's managing director during its acquisition by accounting firm CBIZ Inc. in 2021. Schlisselfeld was at the helm to help shepherd the top-50 accounting firm's transition.On this episode of Talking Tax, Schlisselfeld, senior managing director of CBIZ Marks Paneth, speaks about his experience of overseeing an accounting firm merger, focusing on the challenges faced and lessons learned, as well as sharing advice about how to retain talent and manage major changes.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Kathleen Kerrigan is stepping into her new role as the US Tax Court's chief judge with an overarching goal to help the court in living with the Covid-19 pandemic.Kerrigan says her work will include moving to more in-person trials while still maintaining flexibility. In addition, she hopes to increase electronic filing now that DAWSON—the case management system launched by the court in late 2020—makes that possible.On this week's Talking Tax, Kerrigan also spoke about access to Tax Court records, avenues to advance or resolve cases pre-trial, and work by the court to promote diversity and equity.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The United States ranks first globally for financial secrecy, according to the latest report by the Tax Justice Network and US authorities are trying to do something about it. The Pandora Papers show secretive business structures are thriving in states including Delaware, Nevada, South Dakota, and Wyoming.A few states are taking the problem seriously including New York, which debated but failed to enact the LLC Transparency Act (A9415/S8439) earlier this year. Among other things, the proposed law would require full disclosure of the beneficial owners of limited liability companies and the creation of a publicly searchable database of this information.On this episode of Talking Tax, we hear two perspectives on New York’s proposal. Ryan Gurule, policy director of the Financial Accountability and Corporate Transparency Coalition, contends the states have an important role to play to halt illicit financial flows that facilitate tax evasion and money laundering. Elizabeth “Beth” Garvey, a shareholder in the government policy practice of Greenberg Traurig LLP, cautions that New York’s proposal would create a “backdoor tax” and interfere with the state’s business development objectives. Gurule and Garvey spoke with Bloomberg Tax senior correspondent Michael Bologna.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The July 8 news that the US was canceling a bilateral tax treaty with Hungary that has been in place since 1979 took a lot of people by surprise.While Treasury pointed to conditions in the treaty it said were unfavorable to the US, the announcement also came amid Hungary's continued opposition at the European Union to the 15% minimum tax the Biden administration has championed.On this week's Talking Tax, Sean Foley, the global head of KPMG's transfer pricing dispute resolution network, talks about the implications of the treaty termination, including on dispute resolution and withholding taxes.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Tax-advantaged land deals known as syndicated conservation easements are under increasingly heavy scrutiny from the IRS and Congress.The transactions involve a tax break under tax code Section 170(h) that is designed to encourage property owners to give away the development rights for land or buildings for conservation purposes. Syndicated deals—which involve multiple parties who buy into a property, often based on promises of super-sized deductions worth several times more than their investment—are designated as tax schemes on the IRS's infamous Dirty Dozen list.The IRS has been fighting some of these deals in court, while legislation targeting the practice has progressed on Capitol Hill, albeit slowly.On the latest episode of Talking Tax, Tabetha Peavey, an attorney adviser for the Tax Law Center at New York University Law, and Rep. Mike Thompson (D-Calif.), who has introduced legislation targeting the deals, discuss syndicated easements. Peavey explains how the transactions work and what the IRS has done to stop what it considers to be abusive behavior. Then Thompson offers his thoughts on whether this is the year that a long-simmering proposal to restrict the deals makes it through Congress.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The Biden administration and Democratic lawmakers are quickly running out of time to move a revamped tax, climate, and health care package before the midterm elections.Biden's broad "Build Back Better" agenda stalled in December when Sen. Joe Manchin (D-W.Va.), a pivotal vote in the evenly split chamber, announced he wouldn't support it. Senate Majority Leader Chuck Schumer (D-N.Y.) has been negotiating with Manchin about a narrower bill focused on clean energy incentives, health care, and tax hikes on corporations and the wealthy.There have been some recent signs of progress, with tentative agreements on prescription drugs and extending the solvency of Medicare. But there are still many issues to hash out and not much time to do it.On the latest episode of Talking Tax, Capitol Hill reporters Kaustuv Basu and Zach C. Cohen break down the state of the negotiations. They cover what's in, what's out, and what obstacles remain.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The electric vehicle market in the United States is reaching an inflection point as companies look to boost manufacturing at the same time that two more large automakers are on the verge of losing a critical consumer incentive.The $7,500 electric vehicle tax credit begins phasing out at 200,000 vehicles sold per manufacturer, a threshold General Motors Co. and Tesla Inc. hit years ago. Ford Motor Co. and Toyota Motor Corp. are quickly approaching that sales milestone, which has automakers and EV advocates looking to Congress to step in.Democrats remain interested in ways to expand the EV credit, but that effort is wrapped up in the Biden administration's stalled tax, climate, and social spending plan.Ellen Hughes-Cromwick, a senior resident fellow for climate and energy at the think tank Third Way, is the guest on the latest episode of Talking Tax. Hughes-Cromwick—who previously worked at the Commerce Department and Ford—discusses growth in the electric vehicle sector, breaks down the argument for expanding the federal tax credit, and explains what it will take to create a market for used EVs.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.