Podcast appearances and mentions of andrew velarde

Send us a Text Message.Tax Notes managing legal reporter Andrew Velarde breaks down the Supreme Court's decision in Moore v. United States and its implications for the future of tax.To hear from the Moores' lawyers, watch the upcoming Taxing Issues webinar here.Listen to our previous Moore episodes:A Recap of SCOTUS Oral Arguments in Moore v. United StatesMoore Money, More Tax Problems? Analyzing Moore v. United StatesFor additional coverage, read these articles in Tax Notes:Moores' Counsel Says Case Signals Court Is Not Open to Novel TaxesSupreme Court Says Transition Tax Is Constitutional in Narrow RulingAnalysis: What's at Stake With Moore v. United States: TranscriptFollow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Tax Notes managing legal reporter Andrew Velarde discusses the economic substance doctrine dispute in Liberty Global Inc. v. United States and its potential implications. For previous Moore episodes, listen to the following:A Recap of SCOTUS Oral Arguments in Moore v. United StatesMoore Money, More Tax Problems? Analyzing Moore v. United StatesFor additional coverage, read these articles in Tax Notes:ABA Section of Taxation Meeting: Liberty Global Is a Warning Against High-Level Business PurposeLiberty Global Appeals Economic Substance Loss to Tenth CircuitLiberty Global Promises Economic Substance Doctrine AppealEconomic Substance Doctrine Constrains Liberty GlobalFollow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.This episode is sponsored by TaxBandits. For more information, visit taxbandits.com and use promo code TaxNotes5.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Tax Notes managing legal reporter Andrew Velarde breaks down the Supreme Court's oral arguments in Moore and predicts what's next for the case.For additional coverage, read these articles in Tax Notes:Government May Have Upper Hand in Moore, but Court May Go NarrowMoore Sold Shares in Transition Tax Company for Big GainMoores Fire Back That Macomber Is Controlling, Not Mere DictumTransition Tax Drafter: Quit It With ‘Mandatory Repatriation Tax'Small Business Groups Enter the Moore Fray in Defense of the TaxMoore Amicus Offers Supreme Court Off-Ramp From Realization QueryMacomber Dictum Not Controlling in Moore, Government SaysListen to our previous Moore episode: Moore Money, More Tax Problems? Analyzing Moore v. United StatesTo hear the full oral arguments, visit supremecourt.gov/oral_arguments/argument_audio/2023 In our “Editors' Corner” segment, Błażej Kuźniacki, senior manager at the International Tax Services at PwC Netherlands, chats about his Tax Notes piece, “Pillar 2 and International Investment Agreements: ‘QDMTT Payable' Seals an Internationally Wrongful Act.” Follow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Tax Notes reporter Andrew Velarde discusses the latest developments on the final regulations for claiming foreign tax credits, including the IRS's decision to delay implementation and the tax community's response. For more on the foreign tax credits, listen to "The Final Foreign Tax Credit Rules: Complaints and Confusion."For additional coverage, read these articles in Tax Notes:IRS Says It Anticipates Extending FTC Relief Notice Another YearTreasury to Publish FTC Guidance on Pillar 2 Taxes by Year-EndGOP Taxwriters to Air Grievances to OECD Leaders in EuropeSilicon Valley Asks IRS to Extend Foreign Tax Credit ReliefJohnson & Johnson Sees $500 Million Tax Benefit From FTC Reg DelayIRS Offers Temporary Relief From Foreign Tax Credit RulesIn our “Editors' Corner” segment, Christopher Moran, counsel at Venable LLP in Baltimore, chats about his coauthored Tax Notes piece, “Proposed Energy Credit Regulations Limit Clean Energy Investment.” Follow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxstrategies23.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Tax Notes reporter Andrew Velarde discusses the penalty dispute in Farhy v. Commissioner and the case's implications for other penalties and future refund decisions. For additional coverage, read these articles in Tax Notes:In Farhy's Wake, Taxpayer Advocate Renews Call for Penalty ChangeFallout From Farhy on Assessable Penalties Could Be ExtensiveIRS Lacks Assessment Authority for Information Return PenaltiesInformation Return Penalty Assessment Controversy Still SwirlsInformation Return Penalty Assessment Fight Coming to a HeadFollow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Tax Notes reporter Andrew Velarde discusses the tax structure dispute in Whirlpool v. Commissioner and the case's future implications for multinational companies. For additional  coverage, read these articles in Tax Notes: No Full Court Rehearing for Whirlpool, Sixth Circuit SaysWhirlpool Agitated Over Attempt to Brand It a Tax CheatParts Manufacturer Sees Daylight Between Itself and WhirlpoolDOJ Urges Circuit to Reject Whirlpool's Call for RehearingGroups Line Up to Warn Circuit About Whirlpool FalloutWhirlpool Wants Circuit to Give Branch Income Case Another SpinWhirlpool's Circuit Court Loss Could Cost It $95 MillionIn our “In the Pages” segment, Gary Wilcox, a partner at Mayer Brown LLP, chats about his coauthored Tax Notes piece, “Will Jurisdictional Nexus Survive Chevron Step 1?”Follow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the the American Bar Association Tax Section. For more information, visit ambar.org/taxnotes.This episode is sponsored by the UC Irvine School of Law's Graduate Tax Program. For more information, visit https://ce.uci.edu/?utm_source=TNM&utm_medium=podcast&utm_campaign=2022taxnote.This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan Parrish

Tax Notes senior legal reporter Andrew Velarde and contributing editor Robert Goulder discuss the influence of the 2020 U.S. elections on the international tax world. For additional coverage, read these articles in Tax Notes:Biden’s International Tax Proposals Missing Many PiecesEU Hopes to Repair Bilateral Relationship With U.S.Biden Win Brings Hope for Progress in Global Tax TalksTaxOps SALT expert Tram Le talks about her recently published piece, “Simplification Initiatives to Reduce Burdens for Remote Sellers.”**This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes. This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Faye McCrayShowrunner: Paige JonesAudio Engineers: Derek Squires, Jordan ParrishGuest Relations: Nicole White

Tax Notes's Jeremy Scott, Stephanie Cumings, and Andrew Velarde review what happened with tax legislation and guidance in 2019 and what lies ahead in 2020.For additional coverage, read these articles in Tax Notes:Conservatives Worry TCJA Could Be Death Blow to Future Tax CutsSenate Sends $426B in Tax Cuts to Trump's DeskA Look Ahead: Democrats to Stand Behind Wealth Taxes in 2020A Look Ahead: Eyes Still on TCJA International GuidanceA Look Ahead: Parking Regs Should Address Fair Market ValueA Look Ahead: Carried Interest and Form Changes Will Be Focus for Partnerships

Jonathan Curry and Andrew Velarde discuss the draft regulations Tax Notes obtained from the Office of Information and Regulatory Affairs.For additional coverage, read these articles in Tax Notes:New OIRA Drafts Reveal Tweaks to TCJA GuidanceOIRA Leadership Shuffle Opens Door to Tax Reg Review Shake-UpOIRA’s Tax Reg Reviews Remain a ‘Black Box’ Despite Draft RegsSpotlight on OIRA’s Review Process Eases Politicization ConcernsOIRA’s Imprint on Tax Regs Revealed in New Cache of Documents***This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Lynn Nichols Federal Tax Update Podcast June, 04 2019, Episode 41 Listen as Lynn Nichols provides commentary on 8 Items pertaining to current developments in U.S. tax law. Partnerships Can Defer Section 1231 Gain Under O-Zone Rules Partnerships are allowed to defer capital gains under section 1231 at the entity level to take advantage of the Opportunity Zone program, according to a Treasury official. [Tax Notes Today, 5/13/2019, Article by Eric Yauch] IRS Disciplinary Office Targets High-Risk Practitioners The IRS Office of Professional Responsibility is focusing on practitioners deemed tax noncompliant and those assessed return preparation penalties for disciplinary action. [Tax Notes Today, 5/13/2019, Article by Jonathan Curry] Tax Court Moves to Allow Limited Representation The Tax Court hopes its new move to allow limited entries of appearance by practitioners will be helpful to pro se litigants. [Tax Notes Today, 5/13/2019, Article by Andrew Velarde]     Tax Court Issues Order, Form on Limited Appearances The Tax Court issued an administrative order and sample form to permit admitted practitioners to enter a limited appearance at scheduled trial sessions beginning in the 2019 fall term.      Tax Court Provides FAQ on Limited Appearance Procedures The Tax Court released a list of frequently asked questions on procedures that permit admitted practitioners to enter an appearance on behalf of petitioners that is limited to specific dates during a scheduled trial session. Tax Court Holds IRS Notice Can’t Overturn Statute’s Plain Language The Tax Court held that Medicaid waiver payments were not excludable from gross income under section 131 based on the plain language of the statute and an IRS notice could not reclassify the payments to deprive a couple of the earned income tax and additional child tax credits they claimed. [Mary K. Feigh et vir v. Commissioner; No. 20163-17; 152 T.C. No. 15] Tenth Circuit Affirms ESOP Participants Were Related Persons The Tenth Circuit affirmed a Tax Court decision that held the shareholders in an S corporation liable for deficiencies based on its finding that the S corporation and employees that participated in its employee stock ownership plan were related persons under section 267, so payroll expenses that accrued were not deductible until they were paid to employees. [Steven M. Petersen et ux. et al. v. Commissioner; No. 17-9003; No. 17-9004]   Sixth Circuit Affirms Estate, Widow Liable as Transferees The Sixth Circuit affirmed a Tax Court decision that held an estate and a decedent’s widow liable as transferees for a bowling alley business’s unpaid income taxes stemming from the sale of the business in a midco transaction, finding that the Tax Court properly refused to respect several features of the form of the transaction. [Billy F. Hawk Jr., GST Non-Exempt Marital Trust et al. v. Commissioner; No. 18-1534]   Eleventh Circuit Upholds IRS Summonses for Attorney’s Bank Records The Eleventh Circuit, in an unpublished per curiam opinion, affirmed a district court’s decision refusing to quash IRS summonses issued to a bank for an attorney and his law firm’s account records, finding that the arguments were rejected in a prior opinion in a related case that also sought to quash an IRS summons. [Michael R. Presley et al. v. United States; No. 18-15091] Judge Upholds John Doe Summons on Law Firm A Texas law firm failed to persuade a federal judge that the IRS abused the John Doe summons process by requesting information on clients who used the firm’s services to set up offshore accounts and entities. [Tax Notes Today, 5/17/2019, Article by Kristen Parillo] John Doe Summons Enforced for Information on Law Firm’s Clients A U.S. district court granted the government’s petition to enforce an IRS John Doe summons issued to a law firm for information regarding clients who used the firm to set up foreign accounts and foreign entities to conceal taxable income, rejecting the firm’s abuse of process argument and its blanket assertion of the attorney-client privilege. [Taylor Lohmeyer Law Firm PLLC v. United States; No. 5:18-cv-01161]

Eric Yauch and Andrew Velarde highlight the major themes that came up at the American Bar Association Section of Taxation meeting in Washington, including interesting insights into recent and coming regulations. For more coverage of the ABA meeting, read these articles in Tax Notes:IRS Considering More Safe Harbors in O-Zone RulesPartnerships Can Defer Section 1231 Gain Under O-Zone RulesTreasury Carefully Considering Interest Definition in Final RulesTriple Net Lease Changes Likely in Final 199A Safe HarborIRS Won’t Be as Forgiving of TCJA Comment DeadlinesWilkins Predicts Temporary Regs Will Disappear From RulemakingTreasury, IRS Open to Suggestions on PTI SimplificationU.S. Officials Urging Delay of DSTs as Negotiations ContinueLooming Tax Court Trial Will Test Economic Substance DoctrineBridging the Guidance Enforcement Gap Is IRS Priority

Andrew Velarde talks to Joe Calianno of BDO about the pending final guidance on the global intangible low-taxed income provision enacted as part of the Tax Cuts and Jobs Act, and Paige Jones talks to Scott Smith of BDO about the state responses to GILTI.

Jeremy Scott, Stephanie Cumings, and Andrew Velarde provide a review of what happened with tax legislation and guidance in 2018 and what's ahead in 2019.For additional coverage, read these articles in Tax Notes:Neal Planning for TCJA Hearing by January’s EndA Look Ahead: Legislators Queuing Up Multiple Retirement BillsA Look Ahead: Healthcare Tax Policy Could Stem From Divided CongressHouse Passes GOP Tax Bill With No Hope for EnactmentA Look Ahead: Awaiting Clarification of 199A and Audit Regime RulesA Look Ahead: Questions Abound on Exec Comp Grandfathering RuleA Look Ahead: 2019 Should See Final Bonus and Tax Accounting Regs

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 CompletionU.S. Antiabuse Rules, Imperfect International Tax Regs ComingTransition Tax Guidance Will Extend Transfer Agreement Due Date'Guideposts’ Revealed for R&D-intensive Business SpinoffsTreasury Clarifies 199A De Minimis Rules Have Cliff Rental Property Ownership Could Decide 199A EffectsTreasury: Qualified Improvement Property Needs Technical CorrectionBonus Depreciation Regs Unlikely to Be Finalized This Year

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 Computations, Punt on FTC Issues

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.

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.