Tax Notes Talk

Eric Yauch discusses the final rules on the centralized partnership audit regime. For additional coverage, read these articles in Tax Notes : Audit Regime Raises Need for Appeals Guidance Practitioners Suggest Options for Debt Issues in Audit Regime Final Audit Regs Put Focus on Debt Mischaracterization Final Audit Regs Clarify What’s In, What's Out of New Regime New Final Partnership Audit R...

Tax Notes contributing editor Benjamin Willis examines the authority of regulators in interpreting statutory tax provisions, especially in the context of the Tax Cuts and Jobs Act as the role of regulations has become more prominent. Read Willis’s related Tax Notes article .

Robert Goulder discusses the proposal to eliminate the EU's unanimity requirement for tax directives and what that would mean for tax policy. For additional coverage, read these articles in Tax Notes : Should the EU Scrap the Unanimity Requirement? Cost of Unanimity on Tax Rules Will Only Increase, Group Says Proposal to End EU Unanimity Requirement Coming by Year-End EU's Moscovici Says...

Jonathan Curry takes a fresh look at the tax regulatory review agreement between the Office of Management and Budget and Treasury now that the process has had time to play out. For further coverage, read these articles in Tax Notes : OIRA Review of Tax Regs Presses on Despite Shutdown A Look Ahead: Treasury, OIRA to Chart New Territory as Final Regs Flood In Treasury, OIRA Still at Odds Over When...

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 End A Look Ahead: Legislators Queuing Up Multiple Retirement Bills A Look Ahead: Healthcare Tax Policy Could Stem From Divided Congress H...

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...

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

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 Rul...

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...

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 Oppor...

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 HQ...

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 , se...

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 W...

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

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 Intrusi...

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

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 T...

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 Pas...

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 Antiabus...

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...

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.

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.

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

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 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.