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Tax Notes Talk

351 episodes - English - Latest episode: 12 days ago - ★★★★ - 79 ratings

A discussion of cutting-edge developments in tax, including up-to-the-minute changes in federal, state, and international tax law and regulations.

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Episodes

Year-End Collection, Volume 2: Tax Oddities

December 28, 2018 05:00 - 16 minutes - 7.62 MB

In the second volume, reporters highlight the quirkiest tax stories of the year. For coverage of these stories in Tax Notes, see: Meals Deduction Guidance Comes Off the Back Burner New Business Meals Guidance Creates Substantiation Concerns California Pot Money Takes Long, Strange Trip to Bank Historic $5.6 Million Washington State Tax Zapper Case Dismissed  Cheesecake Factory Asks for Cherry on Top

Year-End Collection, Volume 1: Tax Oddities

December 21, 2018 05:00 - 12 minutes - 5.88 MB

Reporters highlight the quirkiest tax stories of the year. As mentioned in the episode, here is a copy of Adolf Hitler's 1926 tax return provided to Tax Analysts. For coverage of these stories in Tax Notes, see: Court Guns Down IRS Arguments Over Deductions for Cowboy Games Hitler’s 1926 Tax Return on Sale for $125,000 Cirque du Soleil Founder’s Space Flight Taxable

Proposed Interest Regs: Key Details

December 14, 2018 14:00 - 21 minutes - 9.9 MB

Emily Foster and Eric Yauch discuss some of the key elements of the recently proposed regulations on the business interest deduction limitation. For more extensive coverage, read these articles in Tax Notes: Interest Rule Leaves Securities Traders in a Jam Interest Regs Muddy Partnership Debt-Equity Decisions Interest Deduction Regs’ Antiavoidance Rule Causes Reassessments Interest Allocation Rules Could Wreak Havoc on Groups Interest Regs Require Taxpayers to Decide on ‘Early Adoption...

International Taxation Conference 2018: A View From India

December 07, 2018 05:00 - 12 minutes - 5.66 MB

David Stewart talks to Porus Kaka at the International Taxation Conference in Mumbai about various tax issues, including India's new permanent establishment concept, taxation of the digital economy, and the effects of the Tax Cuts and Jobs Act. For related coverage, read these articles in Tax Notes: India’s Tax Chief: Digital Taxation Needs Fair Allocation Rules India’s New PE Scheme Limited by Unanswered Questions India Seeks Input on Digital PE for Taxing Foreign Companies India's Equ...

Beyond Wayfair: The Fallout

November 30, 2018 05:00 - 18 minutes - 8.4 MB

Jad Chamseddine and Paul Jones discuss the Wayfair decision and the long-term implications for state and foreign taxes. Listen to previous episodes on Wayfair: Navigating the Post-Wayfair World U.S. Supreme Court Overturns Quill For additional coverage, read these articles in Tax Notes:  Texas Bill Would Provide Statewide Local Tax Rate for Remote Sellers Wayfair Settlement Is a Missed Opportunity South Dakota and Wayfair Litigants Reach Settlement California Looks to Follow South Da...

Amazon Chooses HQ2 Locations

November 22, 2018 05:00 - 6 minutes - 3.11 MB

Lauren Loricchio provides an update on Amazon's choice of two HQ2 locations: Northern Virginia and the borough of Queens in New York City. For more coverage in Tax Notes, read: Louisville Won't Release HQ2 Bid, Despite Amazon Announcement  Amazon's New York City HQ2 Site Eligible for Federal Tax Breaks Georgia First Also-Ran to Reveal Incentives Offered to Amazon Amazon to Split HQ2 Between New York City, Northern Virginia Group Slams Reports of Two Amazon HQ2s as 'Bait and Switch' Be...

The Midterm Elections: Implications for Tax Policy

November 16, 2018 05:00 - 30 minutes - 14.1 MB

A roundup of the November 6 midterm election results. Asha Glover and Stephen Cooper discuss what changes to look for in the new Congress, including the makeup of the House Ways and Means Committee and the tax agendas. Paul Jones and Lauren Loricchio discuss the results in the state gubernatorial races as well as the tax ballot measures approved by state voters. For more coverage in Tax Notes, see: Senators Agree on IRS Reform, Extenders as Lame-Duck Priorities Brady Eyes Dozens of TCJA T...

The Midterm Elections: Implications for Tax Policy

November 16, 2018 05:00 - 30 minutes - 14.1 MB

A roundup of the November 6 midterm election results. Asha Glover and Stephen Cooper discuss what changes to look for in the new Congress, including the makeup of the House Ways and Means Committee and the tax agendas. Paul Jones and Lauren Loricchio discuss the results in the state gubernatorial races as well as the tax ballot measures approved by state voters. For more coverage in Tax Notes, see: Senators Agree on IRS Reform, Extenders as Lame-Duck Priorities Brady Eyes Dozens of TCJA T...

Multiple Trust Planning and 199A Regs

November 09, 2018 05:00 - 12 minutes - 5.72 MB

Jonathan Curry discusses the IRS's rules addressing strategies using trusts to sidestep the section 199A deduction limitations and claim multiple deductions. For more coverage in Tax Notes, see:  199A Regs’ Multiple Trust Rule May Invite Challenges Creating Just One Trust for the 199A Deduction? Think Again Non-Grantor Trusts Still Useful in TCJA Planning IRS Drops Hammer on 199A, SALT Cap Workarounds IRS Likely to Trounce 199A Trust Planning Strategy

Deciphering the New Loss Limitation Rules

November 02, 2018 04:00 - 6 minutes - 2.84 MB

Eric Yauch discusses a provision of the Tax Cuts and Jobs Act that hasn't received a lot of attention: section 461(l), which caps excess business losses at $250,000 for individuals and $500,000 for joint filers. For more coverage in Tax Notes, see: New Loss Limitation Is on Government’s Radar New Loss Limitation Hard to Calculate, Interpret With Other Rules

Brexit: The Tax Implications

October 26, 2018 04:00 - 28 minutes - 13.1 MB

Jeremy Cape of Squire Patton Boggs discusses the tax issues arising from Brexit. For related coverage on Brexit, read these articles in Tax Notes: U.K. Tax is Lesser Concern in No-Deal Brexit U.K. Backs Customs Agents Facing Brexit Capacity Challenge EU, U.K. Leaders Willing to Extend Brexit Transition Period Brexit Talks at Impasse Over Customs Backstop Proposal  EU Proposes 'Least Intrusive' Customs, VAT Checks After Brexit The U.K. Can’t Afford to Become a Tax Haven, Says Labour Po...

The Taxability of Peer-to-Peer Car Sharing

October 19, 2018 04:00 - 14 minutes - 6.53 MB

Andrew Breiner talks to practitioners about the various issues raised by state efforts to tax peer-to-peer car rentals. For related coverage, read these articles in Tax Notes: Illinois Governor Vetoes Car Sharing Bill, Proposes Own Plan States Look to Tax the Car-Sharing Industry Airbnb and the Sharing Economy

ABA Meeting: Key Takeaways

October 12, 2018 04:00 - 10 minutes - 4.71 MB

Andrew Velarde highlights the significant insights from the recent American Bar Association Section of Taxation meeting in Atlanta, where the Tax Cuts and Jobs Act was once again the main topic of discussion. For additional coverage of the ABA meeting, read these articles from Tax Notes: TCJA Shaping Global Discussion as Several Regs Near Completion U.S. Antiabuse Rules, Imperfect International Tax Regs Coming Transition Tax Guidance Will Extend Transfer Agreement Due Date 'Guideposts’ ...

An Overview of the Proposed SALT Regs

October 05, 2018 04:00 - 8 minutes - 4 MB

Amy Hamilton discusses the IRS's proposed regulations addressing workarounds to the cap on state and local tax deductions. For additional coverage of the SALT regs, read these articles from Tax Notes: California Governor Vetoes SALT Deduction Cap Workaround New York Coalition to Fight Federal SALT Regulations The Frivolous Challenge to the SALT Deduction Cap Practitioners Urge Caution in Passthrough SALT Cap Planning New Jersey Won't Scrap SALT Cap Workaround, Despite IRS Regs Treasur...

Proposed GILTI Regs: The Details

September 27, 2018 04:00 - 16 minutes - 7.52 MB

Andrew Velarde and Alexander Lewis provide an in-depth look into the proposed regs on global intangible low-taxed income. Read Tax Notes’ latest coverage of the proposed GILTI regs: Treasury Assuages Some Concern Over GILTI Antiabuse Rule Breadth GILTI Regs Signal Business Interest Limits Might Apply Proposed GILTI Regs Could Result in Taxable Phantom Income Practitioners Bristle at GILTI Antiabuse Provision Practitioners Throw More Shade at GILTI Antiabuse Rules GILTI Regs Focus on Co...

IFA 2018: The Highlights

September 18, 2018 04:00 - 25 minutes - 11.8 MB

Stephanie Johnston, Robert Goulder, and David Stewart highlight the hot topics at the 72nd Congress of the International Fiscal Association recently held in Seoul. Check out these stories for coverage of the 2018 IFA Congress: EU Digital Taxation Plan Is ‘Not a Master Thesis’ OECD Makes Headway on Long-Term Answers to Tax Digital Economy OECD Finalizing Work to Enlist Digital Platforms to Collect VAT Judicial Oversight Important for GAAR Application, Judge Says Germany Wants Progress on...

Navigating the Post-Wayfair World

September 14, 2018 04:00 - 28 minutes - 13.2 MB

Paige Jones talks to Jim Ford of Global Tax Management about how retailers are preparing to collect and remit sales and use taxes in the wake of the U.S. Supreme Court's decision in South Dakota v. Wayfair Inc.

Altera: All You Need to Know

August 31, 2018 04:00 - 13 minutes - 6.17 MB

David Stewart, Kristen Parillo, and Ryan Finley examine the Altera v. Commissioner case — everything leading up to the Ninth Circuit opinion, the withdrawal of the opinion by that court, and the status of the case now.

Proposed 199A Regs: An In-Depth Overview

August 17, 2018 04:00 - 15 minutes - 7.28 MB

David Stewart and Eric Yauch delve into the details of the proposed regulations on the passthrough deduction under section 199A.

Treasury-OMB Tax Reg Agreement

August 10, 2018 04:00 - 15 minutes - 7.22 MB

Jonathan Curry discusses the details of the new agreement between the Treasury Department and the Office of Management and Budget over authority to review tax regulations.

State Responses to the TCJA

July 27, 2018 04:00 - 13 minutes - 5.98 MB

State Tax Notes Chief Correspondent Amy Hamilton examines the impact of federal tax reform on the states and how states are responding legislatively to the Tax Cuts and Jobs Act.

Transfer Pricing Under the TCJA

July 13, 2018 04:00 - 10 minutes - 4.8 MB

David Stewart and Ryan Finley discuss whether the Tax Cuts and Jobs Act will finally end the IRS's poor litigation record in transfer pricing cases.

TCJA: 6 Months Later

June 29, 2018 04:00 - 8 minutes - 3.94 MB

Tax Notes Today Editor in Chief Brett Ferguson discusses where things are with the Tax Cuts and Jobs Act now that it's been six months since the law was enacted.

U.S. Supreme Court Overturns Quill

June 26, 2018 04:00 - 10 minutes - 4.72 MB

Jad Chamseddine talks to David Stewart about the U.S. Supreme Court's decision to overturn Quill in South Dakota v. Wayfair Inc. and the implications of that ruling for state tax collection on remote sales.

Tax Challenges of the Digital Economy

June 06, 2018 04:00 - 23 minutes - 10.7 MB

The director of the OECD's Center for Tax Policy and Administration, Pascal Saint-Amans, and the deputy director, Grace Perez-Navarro, sit down with Worldwide Tax Daily chief correspondent Stephanie Johnston to discuss the challenges arising from taxing an increasingly digital economy.

Tax Challenges of the Digital Economy

June 06, 2018 04:00 - 23 minutes - 10.7 MB

The director of the OECD's Center for Tax Policy and Administration, Pascal Saint-Amans, and the deputy director, Grace Perez-Navarro, sit down with Worldwide Tax Daily chief correspondent Stephanie Johnston to discuss the challenges arising from taxing an increasingly digital economy. We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.

Insights Into TCJA Guidance

May 25, 2018 04:00 - 10 minutes - 4.9 MB

Andrew Velarde and David Stewart take a look back at the American Bar Association Section of Taxation May meeting and highlight the important guidance and developments that were discussed.

A Look Ahead at the ABA Section of Taxation Meeting

May 09, 2018 04:00 - 11 minutes - 5.37 MB

Andrew Velarde provides a preview of the upcoming American Bar Association Section of Taxation May meeting and the important guidance and developments that may be discussed. We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.

A Look Ahead at the ABA Section of Taxation Meeting

May 09, 2018 04:00 - 11 minutes - 5.33 MB

Andrew Velarde provides a preview of the upcoming American Bar Association Section of Taxation May meeting and the important guidance and developments that may be discussed.

Estate Tax Planning Post-TCJA

April 27, 2018 04:00 - 15 minutes - 7.26 MB

Jonathan Curry and David Stewart discuss the tax planning opportunities and challenges arising from changes to the estate tax under the Tax Cuts and Jobs Act.

IRS Reform

April 13, 2018 04:00 - 12 minutes - 5.55 MB

As tax day approaches, Tax Notes Today Editor in Chief Brett Ferguson discusses congressional efforts to reform the IRS, including the Taxpayer First Act and the 21st Century IRS Act.

Drunk Tax History

April 01, 2018 04:00 - 23 minutes - 10.7 MB

In a special April 1 episode of the podcast, tax historian Joseph Thorndike and David Stewart discuss the intersection of U.S. taxes and alcohol.

TCJA's Effect on Law Firms' Tax Practices

March 23, 2018 04:00 - 10 minutes - 5.05 MB

Zoe Sagalow talks to David Stewart about the effect of the Tax Cuts and Jobs Act on law firms' tax practices. Her informal survey of law firms reveals they are already seeing signs of the new tax law spurring more demand for their services that could lead to increased hiring.

Wayfair: The End of Quill?

March 09, 2018 05:00 - 10 minutes - 4.72 MB

David Stewart talks to legal reporter Jad Chamseddine about the Wayfair case pending before the U.S. Supreme Court, which could overturn the Quill decision and lead to a major change in the taxation of online commerce.

Measuring the Success of the TCJA’s Tax Cuts

February 23, 2018 05:00 - 10 minutes - 5 MB

David Stewart and Jonathan Curry discuss the complexity of measuring the impact of the tax cuts under the Tax Cuts and Jobs Act (P.L. 115-97).

Taxing Multinationals

February 12, 2018 05:00 - 23 minutes - 11 MB

David Stewart talks to Bill Parks and Reuven S. Avi-Yonah about taxing multinationals. They discuss the current state of the corporate income tax now that the Tax Cuts and Jobs Act is law and whether there is a better way to apportion income.

Amazon HQ2 Incentives

January 26, 2018 05:00 - 7 minutes - 3.26 MB

David Stewart talks to Lauren Loricchio about her effort to obtain through public records requests data from localities competing for Amazon’s second headquarters project. She found that the localities used various methods to avoid public disclosure of incentives offered to the company, including narrow interpretations of state open record laws and bids submitted through entities not subject to those laws.

Taxing the Digital Economy

January 12, 2018 05:00 - 9 minutes - 4.33 MB

David Stewart talks to Stephanie Johnston about the problem of taxing the digital economy and what the OECD and EU are doing to find solutions to the problem.

Year Ahead: Tax Legislation and Regulations

January 01, 2018 05:00 - 17 minutes - 7.83 MB

David Stewart, Jeremy Scott, and Emily Foster provide a legislative and regulatory preview of the year ahead now that tax reform has passed.

Final Tax Reform Bill

December 18, 2017 05:00 - 16 minutes - 7.75 MB

David Stewart and Jeremy Scott discuss the final version of the tax reform bill, which would permanently cut corporate taxes and temporarily provide relief for individuals through 2025.

Chained CPI in the Tax Reform Bills

December 08, 2017 05:00 - 6 minutes - 2.94 MB

David Stewart talks to Zoe Sagalow about a new estimate of inflation -- the chained consumer price index -- proposed in the House and Senate tax reform bills.

Treasury’s Missing Corporate Tax Incidence Report

November 26, 2017 05:00 - 9 minutes - 4.23 MB

David Stewart talks to Jonathan Curry about Treasury’s removal of an analysis (Technical Paper 5) from its website on who bears the burden of the corporate tax.

Senate Tax Reform Bill

November 15, 2017 05:00 - 15 minutes - 7.04 MB

David Stewart and Jeremy Scott discuss the details of the Senate version of the Tax Cuts and Jobs Act, highlighting the differences between the Senate and House bills. The modified mark of the Senate tax reform bill includes repeal of the Affordable Care Act's individual healthcare mandate and would make tax cuts for individuals temporary.

House Tax Reform Bill

November 08, 2017 05:00 - 25 minutes - 11.8 MB

David Stewart and Jeremy Scott discuss the House Republican tax bill, the Tax Cuts and Jobs Act (H.R. 1).

Budget Reconciliation and Tax Reform

October 27, 2017 04:00 - 10 minutes - 4.86 MB

David Stewart and Jonathan Curry discuss the budget reconciliation process and what it means for tax reform.

Passthroughs and the Unified Tax Reform Framework

October 14, 2017 04:00 - 8 minutes - 4.11 MB

David Stewart talks to Jonathan Curry about the proposal in the “Big Six” tax reform negotiators' unified framework to tax passthrough businesses at a special rate.

Carbon Taxes and Pricing

October 13, 2017 04:00 - 7 minutes - 3.29 MB

David Stewart talks to Carrie Elliot, contributing editor at Tax Notes International, about carbon taxes and carbon pricing. They also discuss carbon taxes in the context of the Paris Agreement.

Alternatives to the State Gas Tax

October 13, 2017 04:00 - 5 minutes - 2.75 MB

David Stewart talks to State Tax Today reporter Paige Jones about states pursuing alternatives to the gas tax.

Kansas Tax Cut Repeal

October 12, 2017 04:00 - 6 minutes - 2.8 MB

Lauren Loricchio and Maria Koklanaris discuss the rollback of the Kansas governor's tax agenda, including ending the exemption for passthroughs.

Data Retrieval Tool and Security Issues

October 12, 2017 04:00 - 8 minutes - 3.71 MB

Zoe Sagalow talks to Luca Gattoni-Celli about the data breach involving the IRS's data retrieval tool (DRT). After this episode was recorded, the IRS confirmed that its revised DRT was reactivated on October 1, 2017, for the 2018-2019 FAFSA form, but not for the 2017-2018 cycle. The IRS declined to provide any update about the timing or scope of the DRT's exploitation by identity thieves, including the number of victimized taxpayers. Tax Analysts will continue pursuing this story and share an...

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