Talking Tax

Michael Hadley and Adam McMahon of Davis & Harman join Andrea L. Ben-Yosef to talk about the key provisions in the Family Savings Act, how it was influenced by RESA, and its prospects for enactment after the mid-term elections. With the Congress racing to stop a government shutdown, does Congress have the attention span to focus on bipartisan retirement plan reforms? For more information, see their Daily Tax Report Insight: Are We on the Verge of the Next Big Pension Bill? A Review of the House-Passed Family Savings Act.

Halliburton Co. is consulting with numerous external advisers to help understand the 2017 tax overhaul, especially provisions for which the IRS hasn’t issued final rules. The law cut Halliburton’s effective tax rate by 10 percent this year and gave the company a more level playing field against its foreign-based competition. Still, it presents continuing business-planning challenges as the new tax code provisions are fleshed out. Myrtle Jones, Halliburton’s senior vice president of tax, joins Bloomberg Tax to discuss how the company is reacting to regulatory challenges and how diversity can drive company innovation. Host: Siri Bulusu. Producer: Nicholas Anzalotta-Kynoch.

Lawmakers have just a few weeks to pass a year-end tax package, amid a calendar shortened by observances honoring the late former president, George H.W. Bush. Bloomberg Tax’s Kaustuv Basu and Allyson Versprille join host Amanda Iacone to discuss the prospects for a lame-duck tax package in the House and Senate. Host: Amanda Iacone. Producer: Nicholas Anzalotta-Kynoch

Kate Kraus joins Andrea L. Ben-Yosef to talk about the partnership audit regulations. Kate recently joined Allen Matkins as a tax partner in the firm’s Los Angeles office. There have been several rounds of proposed, temporary, and final regulations, with the most recent ones issued in August. Kate discusses some key issues to take into account under the new guidance, such as what happens if the partnership representative leaves, taking favorable adjustments into account, and other issues that tax practitioners are dealing with.

Senator Chuck Grassley (R-Iowa) will retake the helm at the Senate Finance Committee next Congress, succeeding current Chairman Orrin Hatch (R-Utah), who’s retiring. Under Grassley’s leadership—he led the committee twice before in the early and mid-2000s—the committee is expected to focus on trade, tax policy, healthcare, and oversight issues. Bloomberg Tax’s Allyson Versprille discusses what’s on tap for the tax-writing panel in 2019 and potential tax items that could be addressed in the lame-duck session before Grassley takes over. Host: Amanda Iacone Producer: Nicholas Anzalotta-Kynoch

In the first episode of The Over/Under, Bloomberg Tax’s Ryan Prete explains the history of outlawed sports betting in America and the U.S. Supreme Court’s recent reversal of the ban. Prete sits down with Richard Auxier of the Tax Policy Center to discuss early tax revenue figures from legalized sports betting, and whether sports betting could serve as an “end all” to state fiscal woes. Prete also talks with Sara Slane of the American Gaming Association about the possibility of a federal sports betting framework. Host: Ryan Prete. Producer: RJ Jewell and Nicholas Anzalotta-Kynoch.

Artificial Intelligence and Big Data are terms that are in the news. Tax practitioners should be aware that the IRS is using these methods to mine for information, and that could impact whether and how their clients are audited. Carina Federico of Crowell Moring, Michelle Schwerin of Capes Sokol, and Travis Thompson of Sideman & Bancroft join Bloomberg Tax’s Andrea L. Ben-Yosef to talk about where IRS is getting its data, how the use of AI will impact enforcement, and what practitioners should be doing now. Host: Andrea Ben-Yosef

Congress will look very different when it gavels in next year with a new House Democratic Majority and an expanded Republican Senate. On this special post-election episode of “Suspending the Rules”—brought to you by Talking Tax— reporters and legislative analysts break down the implications of a divided Congress for a variety of key issues. In this episode: • Bloomberg Government senior congressional reporter Nancy Ognanovich dives into the election returns and dynamics in the new Congress. • Bloomberg Government health policy reporter Shira Stein discusses what’s in store for the Affordable Care Act, “Medicare-for-All,” and drug pricing. • Bloomberg Government homeland security reporter Michaela Ross reviews potential moves on immigration. • Bloomberg Environment editor Rob Tricchinelli talks about what the election could mean for climate policy and environmental regulations. • Bloomberg Tax reporter Stu Basu discusses Democrats’ tax priorities and plans to seek President Donald Trump’s tax returns.

Opportunity zones and opportunity funds were created by the 2017 tax act to encourage business investment in low-income communities. They have attracted a lot of interest because of the tax incentives, including exclusion and deferral of capital gains. IRS released proposed regulations on October 19 that gave practitioners some answers. Bradley T. Borden, a professor of law at Brooklyn Law School, and Alan S. Lederman, a shareholder at the Florida law firm of Gunster, join Bloomberg Tax’s Andrea L. Ben-Yosef in describing these opportunity zones and funds, how practitioners can take comfort in going forward with many of these transactions, what the IRS still needs to address. They also examine how these proposed regulations may influence a taxpayer’s decision to use qualified opportunity funds as a way to replace real estate that is sold on a tax-deferred basis, instead of using a Section 1031 like-kind exchange. For more information, see the article in the Bloomberg Tax Real Estate Journal, Rolling Real Estate Gain into a Qualified Opportunity Fund: Comparison with §1031, by Alan S. Lederman and and Bradley T. Borden (Sept. 5, 2018). Link: https://www.bloomberglaw.com/product/tax/document/XDPG43TG000000.

Intel subsidiary Altera Corp.'s cost-sharing structure—and that of other Silicon Valley companies—lies in the hands of one appellate court judge: Susan Graber. The judge's questioning during recent oral argument in the company’s dispute with the IRS could signal a victory for the government, but all agree Altera probably wouldn’t take that lying down. Will the company find itself at war again over whether it’s going to be forced to include stock compensation in its U.S. taxable income? And what about the controversy sparked over handling opinions by judges who die or otherwise become unavailable before the court is done with a case? In this week’s special edition of Talking Tax, Bloomberg Tax reporter Sony Kassam and legal editor Carolina Vargas get reactions to this second go-round in the Ninth Circuit and take a look at what's ahead. This episode features Patrick Smith, a partner at Ivins, Phillips & Barker; Barbara Mantegani, a tax adviser and founder of Mantegani Tax; Calvin Johnson, a professor at the University of Texas in Austin; and Susan Yorke, an attorney at the California Appellate Law Group. This episode is the final part of a three-part series examining the case. Hosts: Sony Kassam and Carolina Vargas Producer: Nicholas Anzalotta-Kynoch