Tax Notes Talk

Tax Notes Today legal reporter Eric Yauch delves into the recent decisions by several private equity firms to convert to corporations in wake of the Tax Cuts and Jobs Act. For additional coverage, read these articles in Tax Notes : Carlyle’s ‘Full C Corp’ Conversion Differs From Others Private Equity Firms Are Converting to Corps, Sort Of Apollo Joins Fund Manager Bandwagon by Converting to C Corp...

Tax Notes Today reporters Ryan Finley and Jad Chamseddine review several European countries’ unilateral approaches to taxing the digital economy and the U.S. reaction. For additional coverage, read these articles in Tax Notes : France Confident of G-7 Digital Taxation Deal Despite U.S. Probe French Senate Passes DST Despite U.S. Tariff Threats U.K. Proposes Draft DST Legislation Containing Double...

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 Guidance OIRA Leadership Shuffle Opens Door to Tax Reg Review Shake-Up OIRA’s Tax Reg Reviews Remain a ‘Black Box’ Despite Draft Regs Spotlight on OIRA’s Review Pro...

Jared Dunkin, head of tax at a Washington, D.C.-based publicly traded multinational, discusses the role practitioners have in mentoring and developing tax professionals. Dunkin is author of the book , Brass Tax: 14 Actionable Insights to Power Your Success . *** This episode is sponsored by University of California, Irvine Law School’s Graduate Tax Program. For more information, visit law.uci.edu/...

Steve Dixon and Kevin Kenworthy of Miller & Chevalier discuss the U.S. Supreme Court's recent decision to uphold Auer deference in Kisor v. Wilkie and what it means for the Treasury and the IRS. For additional coverage, read these articles in Tax Notes : Auer  Deference Survives, But ‘Neutered’ and ‘Zombified’ U.S. Supreme Court Decision on  Auer  Won’t Affect Tax Cases Conservative Justi...

Kristen Parillo and Ryan Finley discuss the Ninth Circuit's new opinion in Altera v. Commissioner upholding a regulation requiring that parties to a cost-sharing arrangement share stock-based compensation. For additional coverage, read these articles in Tax Notes : Altera , the Sequel — Jurisprudence Catches Up With BEPS Altera  Decision Revives Commensurate With Income Standard Ninth Circuit...

Tax Notes Today State reporter Paige Jones discusses the developments in states since the U.S. Supreme Court's June 21, 2018, decision in South Dakota v. Wayfair Inc . See the Tax Notes Nexus Tracker and these articles for more coverage: One Year Later: Experts Discuss Aftermath, Future Impact of  Wayfair No New Streamlined Member States a Year After  Wayfair NCSL SALT Task Force Contemplates...

Stephanie Johnston discusses the G-20 finance ministers' reaction to the OECD's workplan to achieve consensus on taxing the digital economy. The G-20 finance ministers met recently in Fukuoka, Japan. For more coverage, read these articles in Tax Notes : G-20 Finance Ministers Endorse OECD Roadmap for Digital Economy France Aims for G-7 Consensus to Set Stage for Digital Tax Deal OECD Set...

Professor Yair Listokin of Yale Law School discusses the ways that tax policy has affected past recessions and how it may help or hurt in the next one. He also takes a look at the Tax Cuts and Jobs Act from a macroeconomic tax perspective. Listokin is the author of the book, Law and Macroeconomics: Legal Remedies to Recessions . 

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 Rules Partnerships Can Defer Section 1231 Gain Under O-Zone Rules Treas...

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.

At a breakfast panel of the American Bar Association Tax Section meeting in Washington, David Stewart talks to Lilian Faulhaber and Will Morris about the taxation of the digital economy. Lilian Faulhaber is a professor at Georgetown Law, and Will Morris is the deputy global tax policy leader at PwC.

Tax Notes Today Legal Reporter Eric Yauch discusses the final section 199A regulations and the IRS's FAQ on the application of the new passthrough deduction. For additional coverage, read these articles in Tax Notes :   IRS Sneaks ‘Nasty Surprise’ Into Expanded 199A FAQ Business Separation Under 199A Remains a Mystery Whether a Taxpayer Qualifies for 199A Depends on Who You Ask What Constitut...

In a phone interview, Jonathan Curry talks to Brad Dillon of Brown Brothers Harriman about estate planning trends following the Tax Cuts and Jobs Act, as well as what keeps planners up at night ahead of the 2020 election.

Stephanie Cumings discusses the Opportunity Zone program and the highlights of the new proposed regulations. For additional coverage, read these articles in Tax Notes :  O-Zone Regs May Not Totally Bar Triple Net Leases O-Zone Regs Don’t Address Practical Tiered-Partnership Issue New Proposed O-Zone Regs May Be the Last, Officials Say Carried Interest Benefits Curbed for Some O-Zone Investments

In part 2 of an interview with National Taxpayer Advocate Nina Olson, Tax Notes Today senior reporter William Hoffman and Olson discuss her impending retirement, her work as the national taxpayer advocate, and her future plans.

In part 1 of an interview with National Taxpayer Advocate Nina Olson, Tax Notes Today senior reporter William Hoffman and Olson discuss the filing season, the Taxpayer First Act (H.R. 1957), the disclosure of program manager technical advice, and congressional efforts to get President Trump's tax returns. For additional coverage, read these article in Tax Notes : Treasury Misses Dems’ Deadlin...

Raymond Wynman, the managing director of Global Tax Management’s International Tax practice, discusses the final rules on section 965, specifically the 965(b) basis-shifting election and the specified payment rule.

In our special April Fools' episode, Tax Notes reporters recount some of their favorite stories of tax protester arguments. 

Stephanie Johnston talks to Grace Perez-Navarro, deputy director of the OECD's Centre for Tax Policy and Administration, about its public consultation in Paris to address taxing the digital economy, and Ryan Finley and Johnston discuss the consultation document in detail. For additional coverage, read these articles in Tax Notes : Making Waves: OECD Navigates Debate on Tax Rules for Digital A...

Mike Minihan of BX3 Capital discusses the cryptocurrency market and its regulatory and tax environment.

William Hoffman checks in on the the first round of tax filings under the Tax Cuts and Jobs Act, including the data on refunds and the effect of the government shutdown on the filing season. For more detailed coverage, read these articles in Tax Notes : Refunds Turn Higher, but Treasury Warns of Changes Policymakers Debate Causes, Remedy for Tax Refund Lag Economic Analysis: Will Disappointing Ref...

Kimberly Clausing, the Thormund Miller and Walter Mintz Professor of Economics at Reed College, discusses tariffs, free trade, and globalization. She is also the author of the new book , Open: The Progressive Case for Free Trade, Immigration, and Global Capital .

Richard Joslin, a consultant to EnTrustPermal, discusses how the new business loss and interest expense limitations work together and affect other code provisions. For more details, read Joslin's article in Tax Notes .

Carrie Elliot talks about the changes the Tax Cuts and Jobs Act will bring between now and 2027, including rate increases.