Podcasts about tax notes

Send us a textTax Notes chief correspondent Amanda Athanasiou discusses her recent investigation into the IRS's handling of Freedom of Information Act requests and trends from two decades of agency data.For more, check out the Tax Notes coverage of the IRS FOIA system:IRS FOIA Backlog Expected to GrowFOIA Appeals Fail So Often, Taxpayers See a Broken SystemThe IRS Is Getting Fewer FOIAs. Why Aren't Response Times Improving?Follow us on X:Amanda Athanasiou: @akathanasiouDavid 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.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesProducers: Jordan Parrish, Peyton RhodesAudio Engineers: Jordan Parrish, Peyton Rhodes

Send us a textProfessor Andrew Kahrl, author of The Black Tax: 150 Years of Theft, Exploitation, and Dispossession in America, discusses his argument that local property taxes have contributed to the disenfranchisement of Black homeowners.   Read Thorndike's book review in Tax Notes, "Is the ‘Predatory' Property Tax an Instrument of Oppression?"Listen to more Tax Notes Talk episodes from our critical tax theory series:Addressing Tax Policy Challenges for Workers With DisabilitiesRace-Based Poll Taxes and 20th-Century DiscriminationExamining Treasury's Review of Racial Bias in the U.S. Tax CodeFollow us on X:Joe Thorndike: @jthorndikeDavid 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.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesProducers: Jordan Parrish, Peyton RhodesAudio Engineers: Jordan Parrish, Peyton Rhodes

Send us a textTax Notes contributing editor and historian Joseph J. Thorndike discusses President Trump's referral to “the forgotten man” and how the phrase connects to a conservative case for taxing the rich. Read Thorndike's article in Tax Notes, "The Too-Well-Remembered Man: A Conservative Case for Taxing the Rich."For more coverage, read the following in Tax Notes:Bye-Bye Round Numbers, Hello Rate Tweaks for Rescored TCJA BillMovement on Trump Tax Proposals Is Reconciliation Wild CardMoores' Counsel Says Case Signals Court Is Not Open to Novel TaxesFollow us on X:Joe Thorndike: @jthorndikeDavid 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.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton Rhodes

This Flashback Friday is from episode 245, published last Feb 26, 2012.  Jason interviews author, Amity Shlaes, about her book, “The Forgotten Man: A New History of the Great Depression.” Franklin D. Roosevelt spoke of the forgotten man as the man at the bottom of the economic pyramid, the poor man, the homeless man. Miss Shlaes explains that there is another forgotten man, the taxpayer, based on an algebraic description by William Graham Sumner. Jason and Miss Shlaes explore the concept that the Great Depression was man-made, that the Federal government suppressed the economy and the markets, which slowed recovery. A zombie-like economy has ensued in America, very similar to what happened with Japan's economic downfall, which is still recovering two decades later. Miss Shlaes also shares how the collective or community aspect, particularly farms, encouraged and funded by the government, did not work because of bad stewardship – nobody cared about anything because nobody owned anything. In order for people to care and succeed, they must be allowed to own property, own businesses, and own their homes. Amity Shlaes and Jason move on to discuss “The Greedy Hand,” as it refers to taxation. As Miss Shlaes researched the history of The Greedy Hand, she found that Americans initially resisted tax withholding, that it was not just accepted. Over time, taxation has become extremely complex, and the best solution would be to simplify it again. Miss Shlaes also shares her predictions on inflation for 2012. She encourages people to read, to educate themselves and their children. Amity Shlaes is a syndicated columnist for Bloomberg and a senior fellow at the Council on Foreign Relations. In addition to writing on political economy, she writes on taxes. She is a contributor to Marketplace, the public radio show. She has appeared on numerous radio and television shows over the years. Miss Shlaes was formerly a columnist for the Financial Times and, before that a member of the editorial board of the Wall Street Journal, specializing in economics. In the early 1990s she served as the Journal's features, or "op ed" editor. Prior to that, she followed the collapse of communism for the Wall Street Journal/Europe. Over the years she has published in the National Review, the New Republic, Foreign Affairs (on the German economy), the American Spectator, the Suddeutsche Zeitung and Die Zeit. In 2002, she contributed an article on the US tax code to the thirtieth anniversary anthology of Tax Notes, the scholarly journal. Miss Shlaes has twice been a finalist for the Loeb Prize in commentary, her field's best known prize. In 2002, she was co-winner of the Frederic Bastiat Prize, an international prize for writing on political economy. In 2003, she spent several months at the American Academy in Berlin as the JP Morgan Fellow for finance and economy.     Follow Jason on TWITTER, INSTAGRAM & LINKEDIN Twitter.com/JasonHartmanROI Instagram.com/jasonhartman1/ Linkedin.com/in/jasonhartmaninvestor/ Call our Investment Counselors at: 1-800-HARTMAN (US) or visit: https://www.jasonhartman.com/ Free Class:  Easily get up to $250,000 in funding for real estate, business or anything else: http://JasonHartman.com/Fund CYA Protect Your Assets, Save Taxes & Estate Planning: http://JasonHartman.com/Protect Get wholesale real estate deals for investment or build a great business – Free Course: https://www.jasonhartman.com/deals Special Offer from Ron LeGrand: https://JasonHartman.com/Ron Free Mini-Book on Pandemic Investing: https://www.PandemicInvesting.com      

Send us a textA Tax Notes investigation unveiled how money sheltered in offshore insurance investment vehicles has eluded IRS auditors hampered by poor training and silos within the agency.  Leaked documents obtained by the International Consortium of Investigative Journalists and reviewed by Tax Notes show private placement life insurance structures — a special type of insurance available only to wealthy investors — with millions of dollars set up in offshore tax havens like Belize and the Cayman Islands. Three members of the Tax Notes investigations team explain their reporting process, from choosing the topic to final follow-ups. If you have a tip for the investigations team, reach them at tips.investigations@taxnotes.com or through the Signal app at 347-731-3183.For more, check out the team's coverage on private placement life insurance:Chance of Changes to Life Insurance ‘Wrappers' Dims PostelectionHow Offshore Life Insurance Helps Business Owners Minimize TaxesHigh-End Life Insurance Policies Lured Offshore by Relaxed RulesInside How Private Placement Life Insurance Slips Through the CracksTo hear Senator Wyden's full statement, visit https://www.youtube.com/watch?v=xiez_NnUBZQ.Follow us on X:Lauren Loricchio: @LaurenLoricchioChandra Wallace: @ChandraSWallaceSarah Paez: @PaezWritesKiarra Strocko: @KiarraStrockoDavid Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Send us a textJeff and Scott chat with Cara Griffith, CEO of Tax Analysts about Tax Notes, the main product of Tax Analysts. Tax Notes is a tax practitioner publication catering to tax professionals, and Jeff and Scott talk about who reads Tax Notes, how content is produced, and who the competitors to Tax Notes are.Finally, we discuss Tax Analysts' ownership of the URL https://taxmuseum.org/, which is a direct competitor to the much better http://thetaxmuseum.org. 

Send us a textJānis Taukačs, a partner at Sorainen in Latvia, discusses the Baltic region's tax priorities, as well as his own professional journey through the world of tax. For other episodes from Cape Town, listen to:"From Cape Town: A Sit-Down With South Africa's Top Tax Official.""From Cape Town: Developing Tax Policy for Developing Nations."For more about the Sergei Magnitsky story, read David Stewart's article in Tax Notes, "Death of Russian Lawyer Puts Spotlight on Hermitage Tax Fraud."   For more coverage, read the following in Tax Notes:OECD Framework Discussing Permanent Pillar 2 Safe HarborsFrustration Persists in OECD Framework Over Pillar 1Lithuania Tax Authority Proposes Pillar 2 Implementing RulesLatvian Parliament Passes Global Minimum Tax LegislationFollow us on X: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

Ariel Greenblum is the Editor in Chief of Tax Notes Federal, a weekly journal published by Tax Analysts that features stories and commentary on federal taxation. In this episode of On Tax, Ariel and Cravath partner and host Len Teti branch out into the world of tax journalism, exploring how an early interest in economics and tax law shaped Ariel's path from law student to editor. Ariel also shares what she sees as the hallmarks of a successful editorial process and reflects on the differences between accuracy and clarity in legal writing. Hosted on Acast. See acast.com/privacy for more information.

Send us a textProfessors Kenneth Austin and Hillel Nadler discuss the policies that they believe make the United States a tax haven, and the resulting effects on the economy.For more, read Nadler and Austin's article in Tax Notes, "America the Tax Haven and Its Trade Deficits."Listen to more Tax Notes Talk episodes about tax havens:Bad Credit: A Look at Switzerland's Bank SecrecyLet's Talk Tax Havens: The EU Blacklist and the Pandora PapersFor more coverage, read the following in Tax Notes:EU to Remove Antigua and Barbuda From Tax BlacklistResearchers Try to Quantify Firms' Use of Tax Havens After TCJABEPS Activity May Have Declined in Tax Havens, OECD ReportsMontana DOR Amends Code to Remove Tax Haven LanguageThe EU Tax Blacklist: A Six-Year Journey Toward ComplianceFollow us on X: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

Send us a textJeff and Scott chat with Nana Ama Sarfo, a contributing editor with Tax Notes, with a special interest in covering taxes in the developing world. They chat about the recent deadly tax protests in Kenya, where a tax increase on basic life staples lead to violence in the street, parliament being lit on fire, and death.Get CPE for listening to Tax Chats! Free CPE courses are available approximately one week after episodes are published. Visit https://earmarkcpe.com/ to download the free app. Go to the Tax Chats channel, register for the course, take a short quiz, and earn your CPE certificate. 

Send us a Text Message.Javiera Moraga Valverde, a Chilean lawyer and U.S. law firm associate, discusses her research on how tax systems can harm women via gender-neutral tax policies and shares potential solutions.For more, read Moraga Valverde's article in Tax Notes, "Tax Policy: Is Gender Neutrality Enough?"Listen to more Tax Notes Talk episodes from our critical tax theory series:Gender Equality, Tax, and the PandemicRace-Based Poll Taxes and 20th-Century DiscriminationExamining Treasury's Review of Racial Bias in the U.S. Tax CodeIs IRS Tax Enforcement Colorblind?State Tax Authority and Native Americans: Complex and ConvolutedWealth, Inequality, and Taxes in the U.S.Feminism and the Tax CodeTaxes and the LGBTQ CommunityAddressing Racial Inequity in State and Local Tax PolicyThe Tax Code and Economic Justice in AmericaHow Racial Diversity Shaped U.S. International Tax PolicyFollow us on X:Caitlin Mullaney: @MullaneyWritesDavid Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Send us a Text Message.Tax Notes investigated the Navajo Nation's tax challenges with the IRS and gathered firsthand accounts of how its members navigate a complex filing system with scarce resources and cultural differences.Investigations Editor Lauren Loricchio interviewed two members of the Navajo Nation: Laura Mike, executive director of the Navajo United Way, and Buu Nygren, president of the Navajo Nation. She also spoke with Nick Mattison, a partner at Feferman, Warren & Mattison, who specializes in consumer law.  For additional coverage, read the following articles in Tax Notes:W&M Advances Tribal Child Support Enforcement BillInside the IRS Representation Roadblock Facing Navajo NationLegislation, Outreach Could Help Tribal Taxpayers Access Tax CreditsScarce Resources Leave Navajo Nation With Few Tax OptionsFollow us on X:Lauren Loricchio: @LaurenLoricchioDavid Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Send us a Text Message.Tax Notes contributing editor Marie Sapirie discusses the recent Supreme Court decisions overturning Chevron and defining the statute of limitations period and their potential impact on the future of tax litigation. Listen to our related episodes:Less Is Moore: The Supreme Court's Ruling in Moore v. United StatesPending Supreme Court Cases and the Challenges for Tax PolicyWhat the End of Chevon Deference May Mean For TaxFor additional coverage, read the following articles in Tax Notes:YA Global Pushes Tax Court to Revisit Withholding DecisionAnalysis: Chevron Is Dead. Long Live Skidmore and the APA?Post-Chevron Senate Group Deluging 101 Agencies With LettersLoper Bright Puts Direct File on Shakier Ground, Crapo SaysHouse GOP Chairs Flood Agencies With Loper Bright QuestionsTribune: Loper Bright Merits Review of Partnership Antiabuse RegSupreme Court's Overturning of Chevron Could Cause Tax Shake-UpFollow us on X/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

Send us a Text Message.Tax Notes chief correspondent Amanda Athanasiou discusses the effectiveness of carbon pricing as a climate change mitigation strategy and possible alternative policies. Read Athanasiou's article, "Keeping the Promise of Carbon Taxes in Perspective."Listen to our previous episode on carbon pricing, "Taxing Carbon at the Border." For additional coverage, read the following articles in Tax Notes:Canada's Budget Watchdog Reveals Gag on Carbon Tax DataCarbon Pricing Systems Collected Highest Revenues in 2023Political Messaging Doesn't Aid Carbon Tax Acceptance, Study SaysCarbon Prices Work but the Literature Has Gaps, Study SaysFrance Joins Canada's Emissions Pact Amid Carbon Tax BacklashFollow us on X/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

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

Send us a Text Message.Tax Notes reporter Sarah Paez discusses the proposed tax plans from the United Kingdom's political parties before their upcoming July 4 election. For more coverage, read these articles in Tax Notes:Tories, Labour, Lib Dems Make Tax Pitches to SMEsU.K. Labour Vows to Improve EU Trade Terms, No Council Tax ReformTories Say Labour Will Hike U.K. Capital Gains Tax Post-ElectionU.K. Labour Party's Tax Plans Could Raise Over £8 BillionU.K. Conservatives Plan Further Cuts to Employee TaxesFor more of Dan Neidle's tax coverage, visit taxpolicy.org.uk.Follow us on Twitter:Sarah Paez: @PaezWritesDavid Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Send us a Text Message.Susan Lanham, Amanda Thompson-Abbott, and Tom Norton of Marshall University discuss their research on the earned income tax credit's effectiveness in alleviating poverty.   For more, read Lanham, Thompson-Abbott, and Norton's Tax Notes article, "Assessing the EITC's Role in Poverty Alleviation."For more coverage, read these articles in Tax Notes:CBO Analysis of Taxpayer Race Data Shows DisparitiesRefundable Credit Audits Should Reflect Equity, GAO SaysData Could Help IRS Evaluate ‘Racialized Burdens'Tax Prep Industry Bashes ‘Outdated' EITC ReportRetail Tax Prep Companies Accused of Targeting MinoritiesGAO Finds $22 Billion Sent in Error for Earned Income Tax CreditFollow us on Twitter:Alex Rifaat: @alexrifaatDavid 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 senior legal reporter Nathan Richman discusses the tax implications of the recent financial controversies surrounding Los Angeles Dodgers player Shohei Ohtani and his former translator.For additional coverage, read these articles in Tax Notes:Ohtani's Ex-Translator Agrees to Plead Guilty to Tax ChargeTax May Still Come to Bat in Saga of Ohtani's TranslatorCalifornia Proposal Would Urge Congress to Block Ohtani-Type Deferred PayOhtani's Dodgers Contract Draws California Controller's IreFollow 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

Professor Yariv Brauner of the University of Florida Levin College of Law discusses the challenges facing residence-based taxation and his proposal for a new way to tax individuals. For more, read Brauner's article, "Taxing People, Not Residents."In our “Editors' Corner” segment, Andrey Yushkov, senior policy analyst for the Tax Foundation, chats about his coauthored Tax Notes piece, “Long-Term Trends in State Personal Income Tax.” Follow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by PLI Press. For more information, visit pli.edu/taxnotes.Join the Tax Notes Talk team for our upcoming live recording at the ABA May Tax Meeting on Friday, May 3! Fore more information, visit taxnotes.co/aba.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Tax Notes contributing editor Nana Ama Sarfo discusses the SEC's recently released carbon pricing disclosure rules and their reception from the business community.  For additional coverage, read Sarfo's article in Tax Notes, "Examining the SEC's Simpler Carbon Pricing Disclosure Rules."Follow us on Twitter:Nana Ama Sarfo: @nanaama_sarfoDavid 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 PLI Press. For more information, visit pli.edu/taxnotes.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Tax Notes chief correspondent Stephanie Soong discusses the latest developments surrounding amount B under pillar 1 of the OECD's two-pillar corporate tax reform plan.  Listen to our last podcast on amount B: Pillar 1 Amount B: Disagreements and DividesFor additional coverage, read these articles in Tax Notes:Amount B Transfer Pricing Approach Doesn't Deliver, BIAC SaysAmount B Might Have a Phase 2, Bello SaysAmount B Won't Change Australia's Inbound Distributor ApproachNew Zealand Won't Adopt Amount B Transfer Pricing FrameworkOECD Sets Out Amount B Transfer Pricing Simplification FrameworkAmount B Tax Certainty Is a Red Line for U.S., Bello SaysFollow us on Twitter:Stephanie Soong: @StephanieSoongDavid 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.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Tax Notes contributing editor Ryan Finley discusses the latest developments in three transfer pricing cases — Medtronic, 3M, and Abbott Labs — and their implications for the future. For additional coverage, read these articles in Tax Notes:Business Groups Urge Eighth Circuit to Overturn Tax Court in 3MMedtronic Budges on CUT Method in Round 2 at Eighth CircuitAbbott Labs Revives Fight Over Stock Options in Transfer PricingBlocked Brazilian Income Can't Be Taxed in U.S., 3M Brief Argues3M Challenges Blocked Income Regs at Eighth CircuitGovernment Resumes Defense of Its Transfer Pricing for MedtronicCoca-Cola's Brazilian Income Not Blocked, U.S. Tax Court SaysIn our “Editors' Corner” segment, Edith Brashares, former director in the Treasury Office of Tax Analysis, chats about her coauthored Tax Notes piece, “Is the Economic Analysis Section of Regs Worth the Trouble?” Follow 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.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Join Tom Wheelwright and his guest, Judge Glock, as they explore how the government uses a "Tax and Return" scheme and how the government benefits you receive are null after all the taxes you pay. Judge is a director of research and a senior fellow at the Manhattan Institute and a contributing editor at City Journal. He writes about the intersection of economics, finance, and housing with a perspective informed by his work in economic history. Glock's work has been featured in National Affairs, Tax Notes, the Journal of American History, NPR, the New York Times, and the Wall Street Journal, among other places. Discover how the "Tax and Return" scheme affects you, how your tax dollars are circulated in the system, and the importance of taking control of your taxes, your life, and your future. Learn more about your ad choices. Visit megaphone.fm/adchoices

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 contributing editor Robert Goulder discusses the downward attribution dispute in Altria Group Inc. v. United States and the case's similarities to Moore.Listen to our 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:Analysis: The Excise Power: Altria Waits Its TurnAltria's Case Stayed Pending Realization Decision in MooreAltria Challenges IRS Downward Attribution Control AnalysisFollow us on Twitter:Robert Goulder: @RobertGoulderDavid 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 contributing editor Nana Ama Sarfo discusses global tax transparency efforts, specifically beneficial ownership registries and country-by-country public reporting. For more, read Sarfo's analysis in Tax Notes: New Year, New Expectations for Global Tax TransparencyFollow us on Twitter:Nana Ama Sarfo: @nanaama_sarfoDavid 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 the Tax Attorney Recruiting Event. For more information, visit the-tare.com.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Tax Notes reporters recap some of the strangest stories they encountered in 2023, from a video game that can prepare tax returns to the IRS attempting to seize a 200-year-old Italian cello. For additional coverage, read these articles in Tax Notes:The ‘Gamification' of Tax Return Preparation Has ArrivedTax Wonk Calls Foul on Massachusetts Surtax After NBA Player DepartsTaxpayer Hits Sour Note in Quest to Protect Cello From IRS LevyForged Documents Shatter Iranian Seizure Deduction ClaimStrained Vacation Locales Embrace Tourism TaxesListen to other tax oddities episodes:Year-End Collection: Tax Oddities of 2022Year-End Collection: Tax Oddities of 2021Year-End Collection: Tax Oddities of 2020Follow us on Twitter:Caitlin Mullaney: @MullaneyWritesEmily Hollingsworth: @EmilyHoll9Sarah Paez: @PaezWritesDavid 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 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

In honor of Tax Notes Talk's 300th episode, Tax Notes chief correspondent Stephanie Soong reviews her tax career and coverage of the OECD over the last decade. For additional coverage, read these articles in Tax Notes:Pillar 1 Treaty Safe Harbor May Fall Short of Goals, Group SaysEU Won't Introduce Pillar 1 Directive, Commission Official SaysCanada's Position on Digital Tax Is Unchanged, Freeland SaysMore European Governments Propose Global Minimum Tax BillsKuwait Signs Up to OECD Inclusive Framework and Tax Reform PlanBelgium Sends Draft Pillar 2 Legislation to ParliamentCountries Are Still at Pillar 1 Negotiating Table, Corwin SaysListen to our 200th and 100th episodes:200 Episodes: Tax Notes Talk's Defining InterviewsTax Notes Goes To Court (Again)Follow us on Twitter:Stephanie Soong: @StephanieSoongDavid 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 chief correspondent Amanda Athanasiou discusses the growing global popularity of carbon border adjustment mechanisms, the EU's new regime, and how border adjustments can be used to support carbon pricing and environmental policy. For additional coverage, read these articles in Tax Notes:Official Defends EU CBAM Against Developing Countries' CritiquesAustralia Considers CBAM in Carbon Leakage Measures ConsultationNorway Isn't Obligated to Implement EU CBAM, Government SaysEU Tax Commissioner Seeks to Reassure CBAM CriticsNon-EU Countries Push Back on CBAM at WTO ForumEU Adopts CBAM Reporting RequirementsEU Wants Input on CBAM Phase-In RulesEuropean Parliament Approves Carbon Border Adjustment MechanismFollow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the Tax Attorney Recruiting Event. For more information, visit the-tare.com.This episode is sponsored by the FRA Private Investment Fund Tax & Accounting Forum. For more information, visit fraconferences.com/pif.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Tax Notes contributing editor Nana Ama Sarfo discusses how lawmakers across the globe are looking to taxes to address problems with fast fashion. For additional coverage, read Sarfo's analysis for free in Tax Notes: "The Tax Man Comes for Fast Fashion."Follow us on Twitter:Nana Ama Sarfo: @nanaama_sarfoDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the FRA Private Investment Fund Tax & Accounting Forum. For more information, visit fraconferences.com/pif.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 the Tax Attorney Recruiting Event. For more information, visit the-tare.com.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

In the second of a two-episode series, Tim Jacobs of Hunton Andrews Kurth continues his discussion of the energy credits enacted in the Inflation Reduction Act and the proposed regulations.Listen to the first part of this series: IRA Energy Credits, Part 1: History and Early Guidance For additional coverage, read these articles in Tax Notes:Grouping Rule Could Be Added to Clean Energy Prefiling ProcessEnergy Department Opens Portal for Low-Income Bonus Energy CreditAnalysis: Apprentices and Emergency RepairsAnalysis: For U.S. Territories, IRA Credits Remain a Complicated QuestionAnalysis: Proposed Labor Requirement Regs Contain Few SurprisesIn our “Editors' Corner” segment, Michael Semes, professor of practice in the graduate tax program at the Charles Widger School of Law at Villanova University and of counsel at BakerHostetler, chats about his coauthored Tax Notes piece, “ADP Certiorari Denial Increases SaaS Uncertainty.” Follow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the University of Cincinnati. For more information, visit online.uc.edu/taxation.This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Tax Notes reporter Elodie Lamer discusses the Business for Europe: Framework for Income Taxation (BEFIT) initiative, the European Commission's latest plan to harmonize and streamline certain aspects of corporate taxation. For additional coverage, read these articles in Tax Notes:Analysis: BEFIT for Europe: Must We Do This Again?Global Developments Both Helped and Constrained EU's BEFITEuropean Commission Draws Lessons From Past Failures With BEFITBEFIT to Apply to Pillar 2 Groups, Align Transfer Pricing RulesEU Businesses Want More Involvement in BEFIT PreparationsFollow us on Twitter:Elodie Lamer: @ElodieLamerDavid 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 the University of Cincinnati. For more information, visit online.uc.edu/taxation.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 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 contributing editor Ryan Finley provides an overview of amount B from pillar 1 of the OECD's two-pillar corporate tax reform plan and discusses the fundamental dispute over it. For additional coverage, read these articles in Tax Notes:Analysis: Scoping-Criteria Dispute Overshadows Amount B ProgressAnalysis: OECD Agreement on Amount B Tax Deal Remains ElusiveFollow us on Twitter:Ryan Finley: @ryanmfinleyDavid Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Tom Cullinan, a former IRS official now with Chamberlain Hrdlicka, discusses the basics of the employee retention credit, the recent rise in misleading promotions and fraudulent ERC claims, and the IRS's response.For additional coverage, read these articles in Tax Notes:Employee Retention Credit a ‘Great Concern' for IRS, Werfel SaysIRS May Face Constraints in Quest to Curb ERC AbuseW&M Panel Considers Amnesty for Fraudulent ERC PaymentsWerfel Drops Hint, Seeks Early End to Employee Retention CreditIRS Zeroes In on Erroneous Employee Retention Credit ClaimsIRS Hard Line on ERC Eligibility Earns Kudos From Tax ProsPayroll Companies Likely Contributing to Mistaken ERC ClaimsIn our “Editors' Corner” segment, Naomita Yadav, a partner at Withers in San Francisco, chats about her Tax Notes piece, “Sparing No One: Cross-Border Taxation of Globally Mobile Individuals,” the second in a two-part series. Follow us on Twitter:Caitlin Mullaney: @MullaneyWritesDavid 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 reporters Cady Stanton and Michael Smith discuss the recently passed U.S.-Chile tax treaty and the importance of tax treaties on both a national and international scale. For additional coverage, read these articles in Tax Notes:Chile-U.S. Tax Treaty Gets Senate Approval, Heads to White HouseSenate Scheduled to Vote on Chile-U.S. Tax TreatyTreasury's Treaty Approach Seeks to Avoid Future ComplicationsIn our “Editors' Corner” segment, George Jackson, a professor of management, business, and economics at Virginia Wesleyan University, chats about his Tax Notes piece, “Early History of the Deduction for Interest Paid.” Follow us on Twitter:Cady Stanton: @Cady_StantonMichael Smith: @TaxesMichaelDavid 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 Alexander Rifaat discusses the tax implications of the recently passed debt ceiling bill and gentleman's agreement over IRS funding.For additional coverage, read these articles in Tax Notes:Biden Signs Debt Ceiling Bill Into LawSenate Approves Debt Limit Deal, IRS ClawbacksFreedom Caucus Voices Opposition to Debt Ceiling AgreementFollow us on Twitter:Alex Rifaat: @alexrifaatDavid 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 Andrea Muse provides an update on the state and federal lawsuits challenging Maryland's digital advertising tax. Listen to our previous episodes on this:The Fight Over Maryland's Digital Advertising Tax, Part 1The Fight Over Maryland's Digital Advertising Tax, Part 2For additional coverage, read these articles in Tax Notes:Maryland High Court Hands State Victory in Digital Ad Tax SuitMaryland High Court Focuses on Exhaustion of Remedies in Digital Ad Tax SuitMaryland Urges State High Court to Uphold Digital Ad TaxComcast, Verizon Respond to Professors in Maryland Digital Ad Tax SuitDigital Ad Tax Unconstitutional, Companies Tell Maryland Supreme CourtFourth Circuit Urged to Allow Federal Digital Ad Tax Suit to ProceedMaryland Urges Fourth Circuit to Reject Digital Ad Tax SuitFollow 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

Professors Bridget Crawford and Victoria Haneman discuss the estate and gift tax and how it could apply to the gifts received by Supreme Court Justice Clarence Thomas. For additional coverage, read these articles in Tax Notes:Harlan Crow Dodges Wyden Request for Details on Thomas GiftsWyden May Pursue Harlan Crow's Tax RecordsWyden Asks Harlan Crow for Details of Gifts to ThomasIn our “Editors' Corner” segment, Ellen Aprill, the John E. Anderson Professor of Tax Law Emerita at Loyola Marymount University's Loyola Law School, chats about her Tax Notes piece, “Reviewing For-Profit Philanthropy and the 1969 Tax Reform 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 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

Professor Samuel Brunson of Loyola University Chicago discusses social media tax scams highlighted in the IRS's 2023 “Dirty Dozen” list of scams and how to spot this misinformation. For more, read "Be Wary of Tax Advice on Social Media, IRS Warns," in Tax Notes.In our “Editors' Corner” segment, Robert van Brederode, the founding partner of BrederodeTax LLC, chats about his Tax Notes piece, “Disclosure of Presidential Tax Returns Violates Right to Privacy.” Follow us on Twitter:Cady Stanton: @cady_stantonDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxplanning23.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Tax Notes contributing editor Robert Goulder discusses the history of bank secrecy, Credit Suisse's role in it, and the bank's recent collapse. For additional coverage, read these articles in Tax Notes:Government Goes After ‘Bank Hopping' Couple for FBAR PenaltiesFinance Committee Says Hidden Swiss Bank Accounts Fight Isn't OverUBS May Have Bought Credit Suisse's Undeclared Account TroublesFATCA Shortfalls Bring Calls for Elimination, Better EnforcementFrance Again Denies UBS Whistleblower's Compensation RequestReport: U.K. Residents Have £570 Billion Stashed in Tax HavensFollow us on Twitter:Robert Goulder: @RobertGoulderDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxplanning23.This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax/events.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Tax Notes legal reporter Caitlin Mullaney discusses ChatGPT's understanding of tax. For more, read "Off the Beaten Tax: Could the Robots Be Coming for the Tax Preparers?" in Tax Notes.Follow us on Twitter:Caitlin Mullaney: @MullaneyWritesDavid 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/events.This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxplanning23.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Kyle Pomerleau of the American Enterprise Institute discusses the Biden administration's fiscal 2024 budget and examines how the tax proposals play into the administration's wider political agenda. For additional coverage, read these articles in Tax Notes:White House Budget Plan Targets Wealthy With Tax IncreasesTreasury Green Book Shows Few Major Changes in Tax Policy GoalsBiden Budget Would Raise Taxes on Wealthy to Save MedicareIn our “Editors' Corner” segment, Amish Shah, a partner at Holland & Knight, chats about his upcoming Tax Notes column on the intersection of clean energy and tax. Follow us on Twitter:Alex Rifaat: @alexrifaatDavid 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 Practising Law Institute. For more information, visit pli.edu/taxplanning23.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Tax Notes contributing editor Nana Ama Sarfo discusses digital services taxes and the OECD's goal to solve related challenges through the pillar 1 multilateral convention. For additional coverage, read these articles in Tax Notes:Pillar 1 Tax Convention Talks Hitting Roadblocks, Le Maire SaysAnalysis: DSTs, Destabilization, and the Rocky Road to Pillar 1Netflix Tells OECD to Mull Cultural Levies for DST Rollback ListKenya Urges Narrower DST Removal Scope for Wider Tax Deal Buy-InOECD Consults on DST Rollback, Global Minimum Tax ImplementationU.K. Will Consider Extending DST if Pillar 1 Is DelayedFollow us on Twitter:Nana Ama Sarfo: @nanaama_sarfoDavid 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 Practising Law Institute. For more information, visit pli.edu/taxplanning23.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Tax Notes contributing editor Ryan Finley discusses the IRS's major win in 3M and how it may affect other transfer pricing cases. Listen to related episodes:Transfer Pricing Litigation Update IITransfer Pricing Litigation UpdateCoca-Cola Transfer Pricing Challenge FizzlesFor additional coverage, read these articles in Tax Notes:Analysis: 3M and the Renaissance of the Commensurate With Income StandardSupplemental Briefing Requested in Coca-Cola Transfer Pricing CaseTax Court Rejects 3M's Challenge of Blocked Income RegsAnalysis: Brazilian Transfer Pricing Reforms Ease U.S. Tax FrictionsFollow us on Twitter:Ryan Finley: @ryanmfinleyDavid 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.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Tax Notes legal reporter Nathan Richman talks with IRS Criminal Investigation Deputy Chief Guy Ficco about the upcoming Advance Collaboration Data Center and other CI initiatives. For additional coverage, read these articles in Tax Notes:IRS Starts Showing Tax Fraud Fruits of Pandemic InvestigationsFirst Update to IRS's Bank Secrecy Act Data Analysis Coming SoonIRS Criminal Investigators Want to Keep Talking About Bank DataIRS Looking for Real Tax Crime in Virtual RealityIRS Teams Collaborating to Thwart Emerging Cybercrimes and FraudCI Chief Has a Big Plan for How to Find Tax Dirty DeedsIn our “Editors' Corner” segment, Sharon Katz-Pearlman, a shareholder with Greenberg Traurig's global tax practice in New York, chats about her Tax Notes piece, "Definitely Not Boring: The U.N. Tax Committee and OECD Collide.”  Follow 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.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Tax Notes reporters Sarah Paez and Kiarra Strocko discuss what they found in an exploration of the OECD-supported mediation process for multinational corporations. For more, read Paez and Strocko's article in Tax Notes, "OECD Corporate Mediation Lacks Teeth on Tax Matters, Critics Say."In our “Editors' Corner” segment, Abraham Leitner, a director at Goulston & Storrs PC, chats about his coauthored Tax Notes piece, " Reexamining Underwater Lease Assumption Transactions.” Follow us on Twitter:Sarah Paez: @PaezWritesKiarra Strocko: @KiarraStrockoDavid 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.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart

Tax Notes contributing editor Joseph J. Thorndike discusses the release of former President Trump's tax returns and how they may influence the discourse around disclosure in the next presidential election.To see the collection of presidential tax returns, visit taxnotes.com/tax-history-project.For additional coverage, read these articles in Tax Notes:Watchdog Calls for TIGTA Inquiry Into IRS Trump AuditsNearly 6,000 Pages of Trump Returns Released, but Not IRS FilesTrump and His Tax Returns Likely Fodder for Next CongressJCT: Audit of Trump Returns Relied on Accuracy of Paid PreparersWays and Means Votes to Release Trump Tax InformationFollow us on Twitter:Joe Thorndike: @jthorndikeDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the District of Columbia Bar Taxation Community. For more information, visit https://site.pheedloop.com/event/TaxConference2023/home/?utm_source=TaxNotes&utm_medium=Banner&utm_campaign=TaxConference&utm_id=TaxConference.This episode is sponsored by the Tax Attorney Recruiting Event. For more information, visit the-tare.com.This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner and Audio Engineer: Jordan ParrishGuest Relations: Alexis Hart