Tax Notes managing legal reporter Caitlin Mullaney explores the Supreme Court’s oral arguments in V.O.S. Selections and Learning Resources and predicts whether the Court will strike down President Trump’s tariffs. 

For related tax news, read the following in Tax Notes:

• Michigan Agencies Forecast Tariff Impacts on Prices, Jobs
• Supreme Court Justices Question Trump's IEEPA Tariffs
• Trump-Xi Summit Yields Lower Tariffs All Around

**
This episode is sponsored by Avalara. For more information, visit avalara.com.

***

Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes

****
This episode is sponsored by Portugal Pathways. For more information, visit portugalpathways.io.

This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Carolyn Schenck, former IRS national fraud counsel, shares insights from decades at the agency, including her pioneering role and her recent move to private practice. 

For related tax news, read the following in Tax Notes:

• Fresh Look at Exempt Orgs Could Be Good, Former CI Employee Says
• Move to Direct IRS CI at Left-Leaning Groups Is Questioned
• ‘Tax Enforcement Is Not Dead,’ Departing IRS Fraud Counsel Says

**
This episode is sponsored by Avalara. For more information, visit avalara.com.

***

Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes

****
This episode is sponsored by Portugal Pathways. For more information, visit portugalpathways.io.

This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Former IRS Chief Privacy Officer Kathleen Walters discusses the agency’s data sharing agreement with the Department of Homeland Security, her decision to step down, and life as a working mom.  

For more coverage, read the following in Tax Notes:

• Treasury Looks to Undo Some IRS Resignations
• IRS Posts Thousands of Jobs Amid Workforce Reductions
• IRS Has Answered Immigration Agency's Request for Tax Data

Follow us on X:

• Paige Jones: @PaigeLeeJones
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

**

Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes

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 Narrow
• Moore Sold Shares in Transition Tax Company for Big Gain
• Moores Fire Back That Macomber Is Controlling, Not Mere Dictum
• Transition Tax Drafter: Quit It With ‘Mandatory Repatriation Tax’
• Small Business Groups Enter the Moore Fray in Defense of the Tax
• Moore Amicus Offers Supreme Court Off-Ramp From Realization Query
• Macomber Dictum Not Controlling in Moore, Government Says

Listen to our previous Moore episode: Moore Money, More Tax Problems? Analyzing Moore v. United States

To 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: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest 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 Says
• EU Won’t Introduce Pillar 1 Directive, Commission Official Says
• Canada’s Position on Digital Tax Is Unchanged, Freeland Says
• More European Governments Propose Global Minimum Tax Bills
• Kuwait Signs Up to OECD Inclusive Framework and Tax Reform Plan
• Belgium Sends Draft Pillar 2 Legislation to Parliament
• Countries Are Still at Pillar 1 Negotiating Table, Corwin Says

Listen to our 200th and 100th episodes:

• 200 Episodes: Tax Notes Talk's Defining Interviews
• Tax Notes Goes To Court (Again)

Follow us on Twitter:

• Stephanie Soong: @StephanieSoong
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest 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' Critiques
• Australia Considers CBAM in Carbon Leakage Measures Consultation
• Norway Isn't Obligated to Implement EU CBAM, Government Says
• EU Tax Commissioner Seeks to Reassure CBAM Critics
• Non-EU Countries Push Back on CBAM at WTO Forum
• EU Adopts CBAM Reporting Requirements
• EU Wants Input on CBAM Phase-In Rules
• European Parliament Approves Carbon Border Adjustment Mechanism

Follow us on Twitter:

• David Stewart: @TaxStew
• Tax 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.

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

Wally Hellerstein of the University of Georgia Law School discusses the emerging state guidance for taxing cryptoassets.

For more on the taxation of cryptoassets, listen to "Cryptocurrency and the Newly Proposed Tax Rules on Digital Assets."

For additional coverage, read these articles in Tax Notes:

• OECD Cryptoasset Framework to Come Into Force in 2027
• New Jersey Tax Division: Crypto, NFTs Are Financial Products
• New York Attorney General Proposes to Tighten Crypto Industry Rules
• The State of NFTs: Navigating the Taxation of Digital Assets
• State Guidance on Cryptocurrency and NFTs Needed, Panel Says

Follow us on Twitter:

• David Stewart: @TaxStew
• Tax 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 FRA Private Investment Fund Tax & Accounting Forum. For more information, visit fraconferences.com/pif.

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest 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_sarfo
• David Stewart: @TaxStew
• Tax 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.

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

Sanessa Griffiths of Skadden, Arps, Slate, Meagher & Flom LLP discusses the lack of diversity in the tax bar and recommends ways to fix it.

For more, read Griffiths et al's article, "Diversity in the Tax Bar — Reflections on Lessons Learned and the Path Forward."

For the report mentioned in the intro, visit "Goal III Report 2022."

Listen to more Tax Notes Talk episodes from our critical tax theory series:

• Race-Based Poll Taxes and 20th-Century Discrimination
• Examining Treasury’s Review of Racial Bias in the U.S. Tax Code
• Is IRS Tax Enforcement Colorblind?
• State Tax Authority and Native Americans: Complex and Convoluted
• Wealth, Inequality, and Taxes in the U.S.
• Feminism and the Tax Code
• Taxes and the LGBTQ Community
• Addressing Racial Inequity in State and Local Tax Policy
• The Tax Code and Economic Justice in America
• How Racial Diversity Shaped U.S. International Tax Policy

Follow us on Twitter:

• Caitlin Mullaney: @MullaneyWrites
• David Stewart: @TaxStew
• Tax 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 FRA Private Investment Fund Tax & Accounting Forum. For more information, visit fraconferences.com/pif.

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

Mike Resnick of Eversheds Sutherland discusses the effects on taxpayers of the corporate alternative minimum tax and its recently released guidance.

For additional coverage, read these articles in Tax Notes:

• Proposed Regs for Corporate AMT Will Address Partnership Shares
• Corporate AMT Consolidation Rules Flow From Tax Principles
• Financial Firm Highlights Potential for Corporate AMT Distortion
• Treasury Official Explains Confusing Rule in Corporate AMT Notice
• Corporate AMT Depreciation Tweaks Unsurprising but Welcome
• Guidance Fills In Some Blanks on Corporate AMT

Follow us on Twitter:

• David Stewart: @TaxStew
• Tax 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.

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest 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 Process
• Energy Department Opens Portal for Low-Income Bonus Energy Credit
• Analysis: Apprentices and Emergency Repairs
• Analysis: For U.S. Territories, IRA Credits Remain a Complicated Question
• Analysis: Proposed Labor Requirement Regs Contain Few Surprises

In 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: @TaxStew
• Tax 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.

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

In the first of a two-episode series, Tim Jacobs of Hunton Andrews Kurth discusses the energy credits enacted in the Inflation Reduction Act and the major pieces of guidance released so far. 

Listen to our other episodes on the tax-related provisions in the Inflation Reduction Act:

• The New Excise Tax on Corporate Stock Buybacks
• U.S. Tax Provisions Driving the Fight Against Climate Change
• $80 Billion in New Funding: What’s Next for the IRS?
• Analyzing the Corporate Alternative Minimum Tax

For additional coverage, read these articles in Tax Notes:

• Analysis: Apprentices and Emergency Repairs
• Analysis: For U.S. Territories, IRA Credits Remain a Complicated Question
• Analysis: Proposed Labor Requirement Regs Contain Few Surprises

Follow us on Twitter:

• David Stewart: @TaxStew
• Tax 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.

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest 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 BEFIT
• European Commission Draws Lessons From Past Failures With BEFIT
• BEFIT to Apply to Pillar 2 Groups, Align Transfer Pricing Rules
• EU Businesses Want More Involvement in BEFIT Preparations

Follow us on Twitter:

• Elodie Lamer: @ElodieLamer
• David Stewart: @TaxStew
• Tax 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.

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

Tax Notes contributing editor Robert Goulder discusses how Pope Leo XIV’s American citizenship creates a unique tax issue and how the United States may try to avoid taxing the pope.  

For more coverage, read the following in Tax Notes:

• Expats Eye Pope's Tax Woes as Opportunity to Ditch Worldwide Tax
• Analysis: The American Pope and Citizenship-Based Taxation

Follow us on X:

• Robert Goulder: @RobertGoulder
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

**

Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes

Professor Jeremy Bearer-Friend of the George Washington University Law School discusses poll taxes in the 20th century and how they were used to target taxpayers based on race and ethnicity.

For more, read Bearer-Friend's article, "Race-Based Tax Weapons."

Listen to more Tax Notes Talk episodes from our critical tax theory series:

• Examining Treasury’s Review of Racial Bias in the U.S. Tax Code
• Is IRS Tax Enforcement Colorblind?
• State Tax Authority and Native Americans: Complex and Convoluted
• Wealth, Inequality, and Taxes in the U.S.
• Feminism and the Tax Code
• Taxes and the LGBTQ Community
• Addressing Racial Inequity in State and Local Tax Policy
• The Tax Code and Economic Justice in America
• How Racial Diversity Shaped U.S. International Tax Policy

Follow us on Twitter:

• Joe Thorndike: @jthorndike
• David Stewart: @TaxStew
• Tax 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.

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

Robert Kerr, formerly with the IRS and now with Kerr Consulting, discusses latest developments from the IRS, including the tax agency’s plans for a government shutdown and its handling of the employee retention credit.

For additional coverage, read these articles in Tax Notes:

• Looming Shutdown Threatens to Derail IRS’s Progress
• IRS Isn’t Shutdown-Proof After All
• IRS to Scale Back EITC Audits, Citing Racial Disparities
• NTEU: IRS’s Push to Hire 3,700 Auditors Is Doable but Difficult
• IRS Floats Adding Partnerships to Prefiling Compliance Program
• IRS Hopes to Sic 3,700 New Revenue Agents on Big Businesses
• IRS Halts ERC Claims Processing Amid ‘Tsunami’ of Fraud

Follow us on Twitter:

• Jonathan Curry: @jtcurry005
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

**
This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxstrategies23.

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

Garrett Brodeur, a tax attorney based in Washington, D.C., discusses the recently released proposed regulations for the cryptocurrency industry and their potential effect on digital asset transactions.

For additional coverage, read these articles in Tax Notes:

• Tax Pros Wary of Overly Inclusive Crypto Reporting Regs
• Decentralized Exchanges Considered Brokers Under Proposed Regs
• Proposed Regs Provide Guidance on Digital Asset Sales and Exchanges

Follow us on Twitter:

• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

**
This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxstrategies23.

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest 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 Year
• Treasury to Publish FTC Guidance on Pillar 2 Taxes by Year-End
• GOP Taxwriters to Air Grievances to OECD Leaders in Europe
• Silicon Valley Asks IRS to Extend Foreign Tax Credit Relief
• Johnson & Johnson Sees $500 Million Tax Benefit From FTC Reg Delay
• IRS Offers Temporary Relief From Foreign Tax Credit Rules

In 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: @TaxStew
• Tax Notes: @TaxNotes

**
This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxstrategies23.

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

Professor Clint Wallace of the University of South Carolina School of Law discusses his argument for using tax policy to reinforce democracy.

For more, read Wallace's article, "A Democratic Perspective on Tax Law."

Follow us on Twitter:

• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

**
This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxstrategies23.

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

Tax Notes Capitol Hill reporters Cady Stanton and Doug Sword preview what to expect from Congress in tax policy this fall, from a potential end-of-year tax package to IRS funding.

For additional coverage, read these articles in Tax Notes:

• GOP Taxwriters to Air Grievances to OECD Leaders in Europe
• Once Upon a Time: Bipartisan Senate Group OK’d $40B for IRS
• State SALT Workarounds Cost Feds at Least $10 Billion Annually
• Democrats Drew Line in Sand for IRA Provisions but Left IRS Out
• Endgame for Tax Legislation Extra Murky as Budget Impasses Loom
• R&D Expensing Revamp Tops Wish List for Year-End Tax Talks
• One Year Later, IRA’s Clean Energy Credits Remain Unknown to Many
• GOP SALT Cap Plans Overwhelmingly Benefit Wealthy, Report Says

Follow us on Twitter:

• Cady Stanton: @cady_stanton
• Doug Sword: @doug_sword
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

**
This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxstrategies23.

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

John McGowan of HubSync discusses artificial intelligence and its role in the tax field.

For additional coverage, read these articles in Tax Notes:

• AI in the DOR: State Tax Departments Ponder Use of Artificial Intelligence
• IRS Working to Deploy AI Algorithms and Models
• AI Programs Not Reliable Enough Yet for Tax Work, Attorney Says 

Follow us on Twitter:

• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest 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 Progress
• Analysis: OECD Agreement on Amount B Tax Deal Remains Elusive

Follow us on Twitter:

• Ryan Finley: @ryanmfinley
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest 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 Says
• IRS May Face Constraints in Quest to Curb ERC Abuse
• W&M Panel Considers Amnesty for Fraudulent ERC Payments
• Werfel Drops Hint, Seeks Early End to Employee Retention Credit
• IRS Zeroes In on Erroneous Employee Retention Credit Claims
• IRS Hard Line on ERC Eligibility Earns Kudos From Tax Pros
• Payroll Companies Likely Contributing to Mistaken ERC Claims

In 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: @MullaneyWrites
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

Tax Notes White House reporter Alexander Rifaat discusses the Biden administration’s economic plan called “Bidenomics” and its effect on tax.

For additional coverage, read these articles in Tax Notes:

• National Economic Council Touts Impact of Biden Tax Incentives
• Biden Extols the Virtues of ‘Bidenomics’
• Treasury Links Construction Surge to CHIPS and IRA Credits

Follow us on Twitter:

• Alex Rifaat: @alexrifaat
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

Tax Notes contributing editor Ryan Finley discusses the current transfer pricing landscape, including where things stand in the Facebook and Coca-Cola cases. 

For more coverage, read the following from Finley in Tax Notes:

• Analysis: The CUT Method: It's Not What It Used to Be
• Analysis: The CUT Method: Same as It Ever Was?
• Analysis: On Periodic Adjustments, Facebook Opinion Suggests A Middle Road
• Analysis: For the IRS, Facebook Is a Reminder to Stick to the Script
• Analysis: Medtronic II: Do the Transfer Pricing Regs Swallow Themselves?
  
  

Follow us on X:

• Ryan Finley: @RyanMFinley
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

**

Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes

Manal Corwin, the new director of the OECD's Centre for Tax Policy and Administration, discusses her vision for the organization and the latest updates on the inclusive framework and two-pillar project.

For additional coverage, read these articles in Tax Notes:

• Vietnam Proposes Global Minimum Tax Rules to Apply in 2024
• BIAC Calls for More Consultations on Global Minimum Tax Rules
• U.K. Adopts Accounting Standard Changes for Pillar 2 Tax Rules
• Beyond the Numbers: Another Look at the JCT Pillar 2 Report
• Digital Taxes Won’t Go Away Anytime Soon, U.N. Official Says
• Autonomous Business Activities Exempt From OECD Amount A Tax Rules
• OECD Seeks Simpler Transfer Pricing With Amount B Consultation
• Countries Advance Pillar 1 Adoption, Extend Digital Tax Freeze

Follow us on Twitter:

• Stephanie Soong: @StephanieSoong
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

Professor Hank Adler of Chapman University discusses the income realization requirement dispute in the transition tax case Moore v. United States before the Supreme Court, and its implications on the U.S. tax system.

For additional coverage, read these articles in Tax Notes:

• News Analysis: Limiting the Fallout From Moore
• Supreme Court to Hear Transition Tax Case With Vast Implications

Follow us on Twitter:

• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

Marna Ricker, EY’s global vice chair of tax, discusses how international tax advisers and corporate tax clients have handled recent tax reforms and what to expect next.

For additional coverage, read these articles in Tax Notes:

• Extended OECD Digital Tax Ban Will Hurt Canada, Freeland Says
• Countries Advance Pillar 1 Adoption, Extend Digital Tax Freeze
• European Tech Companies Push for EU Action on Digital Taxes
• Australia Mulls More Pillar 2 Deferred Tax Break Disclosure Rules

Follow us on Twitter:

• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

Professors Kathleen DeLaney Thomas and Erin Scharff discuss fake tax news and the effect it has on public policy.
 
For more, read the professors' article "Fake News and the Tax Law."

Follow us on Twitter:

• Robert Goulder: @RobertGoulder
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest 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 House
• Senate Scheduled to Vote on Chile-U.S. Tax Treaty
• Treasury's Treaty Approach Seeks to Avoid Future Complications

In 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_Stanton
• Michael Smith: @TaxesMichael
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

Steve Rosenthal of the Urban-Brookings Tax Policy Center reviews the GOP tax package approved by the House Ways and Means Committee, specifically the proposed individual and business tax cuts.

For additional coverage, read these articles in Tax Notes:

• House Tax Bill Racing Toward Floor Vote but Has a SALT Problem
• Ways and Means GOP Votes to Advance Tax Package
• GOP Introduces Tax Package to Kick Off Tax Bill Negotiations
• House Tax Bill to Focus on TCJA Extensions

Follow us on Twitter:

• Cady Stanton: @cady_stanton
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

Scott Peterson of Avalara discusses the South Dakota v. Wayfair decision, including how companies and states are faring five years later and what could be next with sales tax nexus.

For additional coverage, read these articles in Tax Notes:

• Quad Graphics Urges Supreme Court to Take Up Sales Tax Appeal
• South Dakota’s Deb Peters Discusses Wayfair Five Years Later
• No Need to Hear Sales Tax Dispute, North Carolina Tells SCOTUS
• Halstead Bead Asks Fifth Circuit for Relief From Louisiana's Tax System
• North Carolina Institute Urges SCOTUS to Hear Sales Tax Dispute
• Arizona Lawmakers Consider Sales Tax Simplification Bill
• Panelists: Post-Wayfair Nexus Thresholds, Retroactive Application Still Unresolved

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest 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 Law
• Senate Approves Debt Limit Deal, IRS Clawbacks
• Freedom Caucus Voices Opposition to Debt Ceiling Agreement

Follow us on Twitter:

• Alex Rifaat: @alexrifaat
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

Tax Analysts’ chief economist Martin Sullivan provides an overview of the state of the economy and how the recent debt limit bill could affect it.

For additional coverage, read these articles in Tax Notes:

• House Sends Debt Limit Bill, IRS Cuts to Senate
• Did the Pandemic Help or Hurt the Economy?

Follow us on Twitter:

• Marty Sullivan: @M_SullivanTax
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

Former IRS Commissioner David Kautter, now with RSM, discusses the recently released report on the feasibility of an IRS-run direct file program.

For additional coverage, read these articles in Tax Notes:

• Free Direct-File Pilot Will Launch Next Year, IRS Says
• Report of Free File Prototype Irks Top Senate Finance Republican
• Use of Free File Service Dropped This Filing Season, TIGTA Finds
• Will Free File Alliance Survive Competition From the IRS?

Follow us on Twitter:

• Jonathan Curry: @jtcurry005
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

Ellen Aprill of UCLA discusses the legal battle between Harvard and the Trump administration over the university's tax-exempt status and the recourses that an exempt organization may have if its status is revoked.

For more, read Aprill's article, "Revoking Tax Exemption for Pursuit of DEI and Other Alleged Forms of Discrimination."

For more coverage, read the following in Tax Notes:

• Flood of New Briefs Support Ending Johnson Amendment Restrictions
• Senate Dems Seek Probe of Trump's Challenge to Harvard's Exemption
• Trump Questions Harvard's Tax-Exempt Status
  
  

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• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

**

Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes

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 1
• The Fight Over Maryland’s Digital Advertising Tax, Part 2

For additional coverage, read these articles in Tax Notes:

• Maryland High Court Hands State Victory in Digital Ad Tax Suit
• Maryland High Court Focuses on Exhaustion of Remedies in Digital Ad Tax Suit
• Maryland Urges State High Court to Uphold Digital Ad Tax
• Comcast, Verizon Respond to Professors in Maryland Digital Ad Tax Suit
• Digital Ad Tax Unconstitutional, Companies Tell Maryland Supreme Court
• Fourth Circuit Urged to Allow Federal Digital Ad Tax Suit to Proceed
• Maryland Urges Fourth Circuit to Reject Digital Ad Tax Suit

Follow us on Twitter:

• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest 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 Gifts
• Wyden May Pursue Harlan Crow’s Tax Records
• Wyden Asks Harlan Crow for Details of Gifts to Thomas

In 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: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest 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 Change
• Fallout From Farhy on Assessable Penalties Could Be Extensive
• IRS Lacks Assessment Authority for Information Return Penalties
• Information Return Penalty Assessment Controversy Still Swirls
• Information Return Penalty Assessment Fight Coming to a Head

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• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart

Professor Kathleen Claussen of Georgetown Law discusses how the proposed regs for the new clean vehicle tax credit affect the EU and other countries without a free trade agreement.

For additional coverage, read these articles in Tax Notes:

• Volkswagen EV Gains Tax Credit Eligibility
• Treasury Balancing Act on EV Tax Credits Leaves Open Questions
• Taxwriters Criticize Trade Rep on EV Tax Credit Transparency
• EU and U.S. Draw Closer to Energy Tax Credit Deal
• EU Steps Up Its Efforts to Match U.S. Inflation Reduction Act

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• Sarah Paez: @PaezWrites
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest 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_stanton
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

**
This episode is sponsored by Practising Law Institute. For more information, visit pli.edu/taxplanning23.

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

Former IRS Commissioner Fred Goldberg, now with Skadden, shares his thoughts on the IRS’s strategies and proposals outlined in the recently released spending plan for the $80 billion granted by the Inflation Reduction Act.

For additional coverage, read these articles in Tax Notes:

• Werfel to Address IRS Budget and Filing Season at Senate Hearing
• Scholar Suggests Reforming IRS Over Spending More on Enforcement
• Foreign Taxpayers Cautiously Optimistic About IRS’s Payment Plan
• Everybody Wins Under IRS’s New Compliance Model, Observers Say
• Long-Awaited IRS Spending Plan Still Lacks Key Details
• IRS Spending Plan Puts Emphasis on Centralizing Activities
• Analysis: Transforming How the IRS Serves Taxpayers

Follow us on Twitter:

• Jonathan Curry: @jtcurry005
• David Stewart: @TaxStew
• Tax 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.

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest 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 Penalties
• Finance Committee Says Hidden Swiss Bank Accounts Fight Isn't Over
• UBS May Have Bought Credit Suisse’s Undeclared Account Troubles
• FATCA Shortfalls Bring Calls for Elimination, Better Enforcement
• France Again Denies UBS Whistleblower’s Compensation Request
• Report: U.K. Residents Have £570 Billion Stashed in Tax Havens

Follow us on Twitter:

• Robert Goulder: @RobertGoulder
• David Stewart: @TaxStew
• Tax 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.

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest 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: @MullaneyWrites
• David Stewart: @TaxStew
• Tax 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.

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart

Grace Perez-Navarro discusses her long career at the OECD Centre for Tax Policy and Administration and what’s next after her retirement.

For additional coverage, read these articles in Tax Notes:

• Analysis: The OECD’s Push for Women Leaders in Tax Transparency
• Analysis: Grace Perez-Navarro — A Champion of Transparency and Inclusion

Follow us on Twitter:

• Stephanie Soong: @StephanieSoong
• David Stewart: @TaxStew
• Tax 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.

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest 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 Increases
• Treasury Green Book Shows Few Major Changes in Tax Policy Goals
• Biden Budget Would Raise Taxes on Wealthy to Save Medicare

In 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: @alexrifaat
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

Steve Kralik of Armanino discusses the One Big Beautiful Bill Act’s implications for state tax, including the new version of the SALT cap and how states may conform to the changes. 

For more coverage, read the following in Tax Notes:

• Colorado Faces $1.2 Billion Revenue Loss From OBBBA Provisions
• California Advances Conformity Update Bill Without OBBBA Provisions
• Trump Tax Bill Brings State Funding Dilemmas, Conformity Choices

Follow us on X:

• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

**

Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes

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 Says
• Analysis: DSTs, Destabilization, and the Rocky Road to Pillar 1
• Netflix Tells OECD to Mull Cultural Levies for DST Rollback List
• Kenya Urges Narrower DST Removal Scope for Wider Tax Deal Buy-In
• OECD Consults on DST Rollback, Global Minimum Tax Implementation
• U.K. Will Consider Extending DST if Pillar 1 Is Delayed

Follow us on Twitter:

• Nana Ama Sarfo: @nanaama_sarfo
• David Stewart: @TaxStew
• Tax 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.

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart

Tony Santiago of TaxSearch Inc. discusses how the tax profession is changing and offers advice on developing future tax leaders.

For additional coverage, read Santiago's articles in Tax Notes:

• Addressing the Upcoming Tax Leadership Shortfall
• Prepare for the Biggest Tax Leadership Turnover Ever
• How an EY Split-Off Could Affect the U.S. Tax Profession
• Top Seven Reasons a Future Tax Leader Should Work in the Office

Follow us on Twitter:

• David Stewart: @TaxStew
• Tax 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.

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest 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 II
• Transfer Pricing Litigation Update
• Coca-Cola Transfer Pricing Challenge Fizzles

For additional coverage, read these articles in Tax Notes:

• Analysis: 3M and the Renaissance of the Commensurate With Income Standard
• Supplemental Briefing Requested in Coca-Cola Transfer Pricing Case
• Tax Court Rejects 3M’s Challenge of Blocked Income Regs
• Analysis: Brazilian Transfer Pricing Reforms Ease U.S. Tax Frictions

Follow us on Twitter:

• Ryan Finley: @ryanmfinley
• David Stewart: @TaxStew
• Tax 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.

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart