Lawmakers return to Washington next week for the final sprint of legislating before the November elections, on the heels of a failed tax bill vote, and with an appropriations deadline fast approaching. Congress will be under pressure in the next few weeks to reach a deal on government funding to avoid a shutdown on Sept. 30. The Democratic-controlled Senate is set to clash with the GOP House over whether to slash IRS funds or keep them steady, though with so little time left in session lawmakers will likely use a short-term continuing resolution to punt the fight. Also up in the air is whether tax writers will come back to the negotiation table on the $78 billion bipartisan tax package that failed to clear a procedural vote in the Senate just before the August recess. Some lawmakers already are attempting to peel off parts of that tax package—including disaster tax relief and an expansion to the low-income housing tax credit—and it's unclear if those efforts will heat up in September or the lame-duck session. On this episode of Talking Tax, Bloomberg Tax congressional reporters Chris Cioffi and Samantha Handler discuss the weeks ahead in Congress, and how lawmakers are preparing for the 2025 tax cliff. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The market for clean energy tax credits has been booming, with demand and supply skyrocketing since the 2022 tax-and-climate law established new credits and launched a way for energy developers to easily sell those credits to investors. A midyear report by the energy tax marketplace Crux forecasts that energy tax credit transfer deals could total between $20 billion and $25 billion this year, while financial services firm Evercore ISI estimates that more than $100 billion in transferable credits will be generated annually by 2030. Still, risks remain around certain energy tax credits that have yet to see final rules from the Treasury Department, and 2025 will bring additional changes, including the launch of so-called "tech-neutral" credits that aren't tied to any one piece of technology. On this episode of Talking Tax, Bloomberg Tax reporter Caleb Harshberger talks to Crux CEO Alfred Johnson and Hannah Hawkins, principal at KPMG, about how the new market for these credits is developing and what uncertainty remains. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The US Supreme Court brought a muted end last week to its biggest tax case in years, but the arguments that propelled the case are far from over, especially about what the court’s ruling could mean for future attempts to enact a wealth tax. The court voted 7-2 to uphold the mandatory repatriation tax, a one-time tax on past foreign corporate profits. Washington state residents Charles and Kathleen Moore had challenged the constitutionality of the tax, arguing that it had forced them to pay $14,729 in taxes on the profits of an Indian company in which they’d invested even though the company’s profits were never distributed to them. But the case’s significance went far beyond the Moores. Many had feared that striking down the tax not only would lead to billions of dollars in refunds to giant multinational companies that were the tax’s primary targets, but also would call into question a host of other taxes based on similar legal principles. The Supreme Court said the tax was constitutional, and stressed that its ruling was narrow, with any outside issues left for another time. But that left unanswered questions about what the ruling could mean for any future wealth tax. Many such proposals would tax wealthy people’s “unrealized” gains on investments—profits that haven’t actually been distributed or monetized—which was the same issue over which the Moores questioned the repatriation tax. And while the court’s ruling was narrow and set aside the realization issue, at least four of the nine justices supported the idea that income should have to be realized before it could be taxed, a signal that any future wealth tax could have a hard time passing legal muster before the court. This edition of Talking Tax has two interviews with two very different perspectives on the Moore ruling. Bloomberg Tax senior reporter Michael Rapoport spoke first with Chye-Ching Huang, executive director of the Tax Law Center at New York University’s law school, who wanted to see the tax upheld, and then with Andrew Grossman and Jeff Paravano, attorneys for BakerHostetler who represented the Moores and wanted to see the tax struck down. Producer: Matthew S. Schwartz. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Tax directors around the world are grappling with a two-pillar global tax agreement that will require multinational companies to change where and how much tax they pay. As details of how these complex new rules will work in practice come to light, some companies have begun modeling their effect on their tax bills. Rio Tinto PLC, which is part of the OECD's business advisory group, has had a front row seat during the development of the rules and has already put together a team to analyze their impact. On this episode of Talking Tax, we speak with Mark Munsel, general manager of the OECD digital project at Rio Tinto. He heads up the multi-disciplinary team at the company that has been tasked with figuring out how the rules work. Munsel advises companies to start early and begin collecting and organizing the data required to comply with the rules, or risk not being ready when countries start implementing them. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The accounting world has been shaken up with several high-profile mergers and acquisitions among firms in recent years, reflecting the growing needs of clients. Abe Schlisselfeld of Marks Paneth LLP had a front-row seat to this trend, serving as the firm's managing director during its acquisition by accounting firm CBIZ Inc. in 2021. Schlisselfeld was at the helm to help shepherd the top-50 accounting firm's transition. On this episode of Talking Tax, Schlisselfeld, senior managing director of CBIZ Marks Paneth, speaks about his experience of overseeing an accounting firm merger, focusing on the challenges faced and lessons learned, as well as sharing advice about how to retain talent and manage major changes. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Kathleen Kerrigan is stepping into her new role as the US Tax Court's chief judge with an overarching goal to help the court in living with the Covid-19 pandemic. Kerrigan says her work will include moving to more in-person trials while still maintaining flexibility. In addition, she hopes to increase electronic filing now that DAWSON—the case management system launched by the court in late 2020—makes that possible. On this week's Talking Tax, Kerrigan also spoke about access to Tax Court records, avenues to advance or resolve cases pre-trial, and work by the court to promote diversity and equity. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The United States ranks first globally for financial secrecy, according to the latest report by the Tax Justice Network and US authorities are trying to do something about it. The Pandora Papers show secretive business structures are thriving in states including Delaware, Nevada, South Dakota, and Wyoming. A few states are taking the problem seriously including New York, which debated but failed to enact the LLC Transparency Act (A9415/S8439) earlier this year. Among other things, the proposed law would require full disclosure of the beneficial owners of limited liability companies and the creation of a publicly searchable database of this information. On this episode of Talking Tax, we hear two perspectives on New York’s proposal. Ryan Gurule, policy director of the Financial Accountability and Corporate Transparency Coalition, contends the states have an important role to play to halt illicit financial flows that facilitate tax evasion and money laundering. Elizabeth “Beth” Garvey, a shareholder in the government policy practice of Greenberg Traurig LLP, cautions that New York’s proposal would create a “backdoor tax” and interfere with the state’s business development objectives. Gurule and Garvey spoke with Bloomberg Tax senior correspondent Michael Bologna. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The July 8 news that the US was canceling a bilateral tax treaty with Hungary that has been in place since 1979 took a lot of people by surprise. While Treasury pointed to conditions in the treaty it said were unfavorable to the US, the announcement also came amid Hungary's continued opposition at the European Union to the 15% minimum tax the Biden administration has championed. On this week's Talking Tax, Sean Foley, the global head of KPMG's transfer pricing dispute resolution network, talks about the implications of the treaty termination, including on dispute resolution and withholding taxes. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Tax-advantaged land deals known as syndicated conservation easements are under increasingly heavy scrutiny from the IRS and Congress. The transactions involve a tax break under tax code Section 170(h) that is designed to encourage property owners to give away the development rights for land or buildings for conservation purposes. Syndicated deals—which involve multiple parties who buy into a property, often based on promises of super-sized deductions worth several times more than their investment—are designated as tax schemes on the IRS's infamous Dirty Dozen list. The IRS has been fighting some of these deals in court, while legislation targeting the practice has progressed on Capitol Hill, albeit slowly. On the latest episode of Talking Tax, Tabetha Peavey, an attorney adviser for the Tax Law Center at New York University Law, and Rep. Mike Thompson (D-Calif.), who has introduced legislation targeting the deals, discuss syndicated easements. Peavey explains how the transactions work and what the IRS has done to stop what it considers to be abusive behavior. Then Thompson offers his thoughts on whether this is the year that a long-simmering proposal to restrict the deals makes it through Congress. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The Biden administration and Democratic lawmakers are quickly running out of time to move a revamped tax, climate, and health care package before the midterm elections. Biden's broad "Build Back Better" agenda stalled in December when Sen. Joe Manchin (D-W.Va.), a pivotal vote in the evenly split chamber, announced he wouldn't support it. Senate Majority Leader Chuck Schumer (D-N.Y.) has been negotiating with Manchin about a narrower bill focused on clean energy incentives, health care, and tax hikes on corporations and the wealthy. There have been some recent signs of progress, with tentative agreements on prescription drugs and extending the solvency of Medicare. But there are still many issues to hash out and not much time to do it. On the latest episode of Talking Tax, Capitol Hill reporters Kaustuv Basu and Zach C. Cohen break down the state of the negotiations. They cover what's in, what's out, and what obstacles remain. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The electric vehicle market in the United States is reaching an inflection point as companies look to boost manufacturing at the same time that two more large automakers are on the verge of losing a critical consumer incentive. The $7,500 electric vehicle tax credit begins phasing out at 200,000 vehicles sold per manufacturer, a threshold General Motors Co. and Tesla Inc. hit years ago. Ford Motor Co. and Toyota Motor Corp. are quickly approaching that sales milestone, which has automakers and EV advocates looking to Congress to step in. Democrats remain interested in ways to expand the EV credit, but that effort is wrapped up in the Biden administration's stalled tax, climate, and social spending plan. Ellen Hughes-Cromwick, a senior resident fellow for climate and energy at the think tank Third Way, is the guest on the latest episode of Talking Tax. Hughes-Cromwick—who previously worked at the Commerce Department and Ford—discusses growth in the electric vehicle sector, breaks down the argument for expanding the federal tax credit, and explains what it will take to create a market for used EVs. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

A sweeping cryptocurrency bill unveiled earlier this month addresses many of the biggest open questions for the young and volatile asset class, from sanctions compliance to stablecoin oversight. When it comes to the taxation of digital assets, the proposal from Sens. Cynthia Lummis (R-Wyo.) and Kirsten Gillibrand (D-N.Y.) would give the industry much of what it has been asking for. The bill would establish that cryptocurrency rewards created through the processes known as "staking” and “mining" would be taxed when the rewards were sold, rather than when they were created. It also includes a de minimis tax exemption and a narrower definition of brokers for cryptocurrency reporting requirements established in last year's bipartisan infrastructure law. On this episode of Talking Tax, we discuss the implications of the Lummis-Gillibrand bill with Seth Wilks, director of government relations at software company TaxBit, and Omri Marian, a law professor at the University of California, Irvine, School of Law. Wilks discusses the rationale behind the de minimis exemption and other tax proposals, as well as why some things might change as the bill works its way through Congress. Marian explains why he considers the bill's tax title to be "a complete and total surrender" to industry. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

More countries are turning to temporary windfall taxes targeting the huge profits being made by oil and gas companies as prices continue to climb. The UK, Italy, and Argentina, among other countries, have taken different approaches in designing these new taxes. The UK and Italy want to impose a 25% tax on the profits of energy companies to help people facing a cost-of-living crisis, while Argentina wants to impose a 15% tax. On this episode of Talking Tax, senior reporter Hamza Ali spoke with Rhiannon Kinghall Were, a partner and head of tax policy at law firm Macfarlanes. They discuss the different approaches countries can take when applying windfall taxes, and possible long-term consequences of applying these temporary levies. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Wealthy taxpayers are rushing to prepare in case a more generous exemption from the estate tax expires at the end of 2025 along with many of the individual tax cuts from the Republicans' 2017 tax overhaul.  In 2024, taxpayers are exempt from the 40% estate tax on the first $13.6 million of assets passed on to heirs. But the exemption is set to fall by about half, practitioners estimate, if Congress doesn’t act to extend it. People are moving money into different types of trusts now to take advantage of that higher exemption amount.  Deloitte Managing Director Laura Hinson spoke to Bloomberg Tax reporter Erin Schilling about the most popular trust strategies and how to avoid “donor remorse.”  Hinson also explains how the Supreme Court's recent decision Connelly v. United States will affect estate planning. Produced by Matthew S. Schwartz. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

One of the hottest issues in the corporate-tax world right now is about when multinational companies can use the taxes they pay in foreign countries to defray their US tax bills. The Treasury Department has made that process tougher. Last December, it tightened US foreign tax credit rules, narrowing the range of taxes that qualify for it. But many companies have complained that Treasury went too far—rendering some taxes ineligible for the credit even though they’ve been eligible for years, and thus requiring companies to pay taxes twice on the same income. Earlier this month, the chief financial officers of 28 major companies urged Treasury Secretary Janet Yellen to modify the rules. Treasury has acknowledged the companies’ complaints and says it plans steps to address some of them. But it has defended the basic thrust of the rules. Yellen told a Senate committee this week that “these regulations are very important to protect critical interests of the United States." On this episode of Talking Tax, we discuss the dispute over the foreign tax credit rules with Rafic Barrage, a partner in the North America Tax Practice Group at Baker & McKenzie LLP in Washington. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

A 2015 law promised to streamline the Internal Revenue Service's method for auditing partnerships—a type of "pass-through" business where the partners report their share of the proceeds on their personal tax returns. The Bipartisan Budget Act of 2015 included provisions intended to make it easier for the IRS to scrutinize partnerships. But the law created new concerns and unintended consequences for those navigating the audit process, according to Rochelle Hodes, principal of the Washington National Tax office at Crowe LLP. "The simple has become complex," Hodes said on the latest episode of the Talking Tax podcast. She discusses the complexities of the BBA centralized partnership audit regime, who is eligible to opt out, and what partners undergoing an audit need to consider. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

With cash cushions plump with federal pandemic relief dollars and a surge in tax revenues, state legislatures across the country have cut taxes aggressively this year. But several states went further, converting their tiered income tax structures to flat-rate systems. Arizona, Georgia, Iowa, and Mississippi have committed to the flat tax in recent weeks, and Oklahoma is likely to join the group soon. The shift away from graduated income tax structures, which tax higher incomes at higher rates, is a dramatic departure from decades of state tax policy. While the motivations in state capitols vary, flat tax proponents framed their proposals as efforts to limit outmigration and improve their state’s economic horsepower. But skeptics warned of long-term social and economic consequences. On this episode of Talking Tax, we hear two perspectives on this shift. Katherine Loughead, a senior policy analyst with the Tax Foundation, contends flat taxes are more transparent and easier to administer, and boost a state’s competitiveness in a climate where labor and capital are increasingly mobile. Kamolika Das, a state tax policy analyst with the Institute on Taxation and Economic Policy, says flat systems place unfair burdens on low- and middle-income taxpayers, and damage states' capacities to raise revenue and create sensible budgets. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Automation tools increasingly used by seasoned tax professionals are helping to take some of the pain and manual labor out of routine compliance work. That futuristic tech goes beyond robotics process automation and can link together the many programs and platforms that accountants rely on everyday. Those building blocks can automate every step in the tax process from onboarding clients to tax return delivery, according to John McGowan, the CEO of Hubsync and former chief information officer for two Big Four tax practices. On this episode of Talking Tax, McGowan talks to Bloomberg Tax's Amanda Iacone about the challenges that firms face in adopting new ways of working and how it can not only help get work done faster but could make CPA firms more attractive to job candidates and clients alike. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Some or all of the interest paid on student loans can be deducted from your taxes. But despite the proliferation of these types of loans over the years, many taxpayers don't see a real benefit. That's because, unlike with home mortgage interest, the student loan interest deduction has significant limitations and has changed numerous times over the years. Bloomberg Tax columnist Kelly Phillips Erb says Congress needs to rethink how the tax code treats student loans—especially if President Biden forgives a huge swath of them, as he's discussed doing. Kelly also talks about the struggles of paying for higher education and about her family's decision whether to borrow money for her kids, even though she's still paying off her own student loans. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

As part of its bid to join the OECD, Brazil is working on a major overhaul of its rules governing transfer pricing—the way a group’s related entities value transactions between themselves. Historically, Brazil’s transfer pricing rules have relied on a system of fixed margins. But officials have now committed to moving Brazil to the arm’s length standard, the basis of the Organization for Economic Cooperation and Development's guidelines, and many countries’ approaches to transfer pricing. Romero Tavares, a partner at PwC in Brazil, talks to Bloomberg Tax’s Isabel Gottlieb about what the changes mean for multinationals operating in Brazil, benefits and challenges companies will face under the new system, and what to expect as the government moves ahead with the project. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Have you noticed digital works of art with names like Cool Cats, CryptoPunks, and Bored Ape Yacht Club while surfing the web or posting a snarky tweet? They’re all examples of non-fungible tokens, or NFTs, unique digital assets serving as certificates of authenticity for digital products including works of art, music, and collectibles. NFTs are also a surging new industry, expected to reach global sales of $80 billion by 2025. Despite this booming market, state revenue agencies haven’t figured out how to tax or even characterize these digital assets. More than 30 states arguably have authority to collect sales tax on NFTs, but none of them have issued guidance on the subject. Bloomberg Tax took a deep dive into how states might choose to tax NFTs by speaking with two professionals steeped in digital economy tax issues. Wendy Walker, a solutions principal at the tax software company Sovos, talked about the evolution of blockchain technology and the tax treatment of products and services living on blockchains. Kirk Phillips, a member of the American Institute of CPAs’ virtual currency task force, focused on the challenges associated with imposing state sales taxes on NFTs. Wendy and Kirk spoke with Michael Bologna, a senior reporter at Bloomberg Tax covering state and local taxes. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The IRS is struggling. As millions of Americans completed their annual tradition of filing taxes earlier this week, they again connected with a sprawling government agency besieged by issues that money alone can't solve. The IRS is still working through a backlog of unprocessed tax returns and can't keep up with a flood of phone calls from taxpayers looking for help. Bloomberg Tax took a deep dive into the IRS's longstanding structural deficiencies, from an over-reliance on paper documents and outdated technology to a less-than-stellar public perception. We asked current and former government officials, agency watchdogs, and tax professionals to offer their strategy for fixing the IRS. To round out the Fixing the IRS series, former IRS Commissioner John Koskinen and Carlos Lopez, founder of the Latino Tax Professionals Association, join the latest episode of our Talking Tax podcast. They discuss what the agency can do to get back on the right track. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The quick pace of consultations into complex new rules from the OECD is keeping tax practitioners busy. The Paris-based institution has already in 2022 launched several consultations into the “building blocks” of a new international tax system. Pillar One of the plan would reallocate a sliver of the profits of the largest and most profitable businesses to countries where they make sales. Pillar Two would establish a 15% global minimum tax. Tim Sarson Partner, U.K. head of tax policy at KPMG U.K., talks with Bloomberg Tax’s Hamza Ali about the emerging rules in the latest episode of Talking Tax. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The OECD's Inclusive Framework on Base Erosion and Profit Shifting is aiming to help developing countries implement a global agreement to change how multinational companies are taxed, according to the co-chair of its steering committee. The agreement, which more than 130 countries signed up to in October, has two pillars. Pillar One reallocates a portion of the largest multinationals’ profits to market jurisdictions, while Pillar Two creates a global minimum tax rate of 15%. The two pillars come with enormous complexities, meaning some countries will need help to keep up with the pace of implementation, says Marlene Nembhard-Parker, chief tax counsel for legislation, treaties, and international tax matters at Tax Administration Jamaica and co-chair of the Inclusive Framework Steering Group. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Countries are under pressure to finalize and sign the text of the OECD's multilateral tax treaty, one part of the international tax deal known as Pillar One, by the end of June.  Several OECD officials, including Manal Corwin, director of the organization's Center for Tax Policy and Administration, have reported significant progress on finalizing the document. But negotiations have hit a snag. The problem area is treatment of another part of Pillar One, known as Amount B, that's meant to simplify the way businesses value intercompany marketing and distribution transactions. The US and India, in particular, have butted heads over whether the measure should be mandatory.  In this week's episode of Talking Tax, Bloomberg Tax reporter Lauren Vella sits down with Dr. Santiago Gomez Cifuentes, head of congressional affairs at the Colombian Embassy in Washington, to talk about progress made on the Organization for Economic Cooperation and Development-led deal and what's holding back the completion of Pillar One. Gomez Cifuentes is in close contact with the Colombian delegation to the OECD, and serves as a go-between representing Colombian interests in conversations with US lawmakers. He spoke with Bloomberg Tax on his own behalf and doesn't represent the official position of the Colombian government. They also talk about Colombia's interest in the US Inflation Reduction Act and tax incentives that could boost mineral exports from Latin American countries. Produced by Matthew S. Schwartz.

The OECD released a draft framework March 22 that would standardize how global tax authorities regulate and share tax information related to cryptocurrency assets. The draft—called the Crypto-Asset Reporting Framework, or “CARF”—includes model technical rules and a commentary written for wide adoption and data-sharing among tax administrations. Countries that adopt the Organization for Economic Cooperation and Development's standards would require individuals and entities that “provide services to exchange crypto-assets against other crypto-assets, or for fiat currencies” to identify their customers and report the aggregate values of the exchanges and transfers on an annual basis. Buchanan Ingersoll & Rooney PC international tax attorney Sahel Assar called the draft proposal a “tsunami” of regulation coming for cryptocurrency and related industries. Regulation, she says in our latest podcast, helps to legitimize the crypto industry. The OECD is gathering public comments on the draft through the end of April. It aims to update the proposal and present it at the October meeting of the Group of 20. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Recent court rulings striking down two Internal Revenue Service reporting requirements suggest the agency may need to change its procedures so that its rules will hold up in court. The U.S. Court of Appeals for the Sixth Circuit struck down a tax reporting requirement on March 3 in Mann Construction, Inc. v. United States. That decision was cited by the U.S. District Court for the Eastern District of Tennessee when it struck down a separate reporting requirement on March 21 in CIC Services, LLC v. IRS. The decisions come as the Treasury Department, and the IRS within it, face increasing scrutiny over whether their tax rulemaking procedures have met legal requirements. On the latest episode of Talking Tax, Melissa Wiley, Member in Caplin & Drysdale's D.C. office, and Kristin Hickman, law professor at the University of Minnesota, discuss what the decisions could signal about how courts will approach federal tax rulemaking procedures. They speak with Bloomberg Tax's Aysha Bagchi and Jeff Leon. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Gasoline prices have reached record highs in recent weeks, spurring lawmakers across the country to look for ways to offer some relief. A popular target: the excise taxes the federal government and states collect to fund transportation programs. Some congressional Democrats have floated a suspension of the 18.3 cent-per-gallon federal gas tax, while many governors are pursuing state holidays that could provide some temporarily relief to drivers. Temporarily ditching the gas tax would offer some obvious political benefits for lawmakers running for re-election this year. But how much would it actually help consumers with the national average for regular gasoline up to well over $4 a gallon and gas prices nearing $6 a gallon in California? Lucy Dadayan and Howard Gleckman of the Urban-Brookings Tax Policy Center appear on the latest episode of our weekly Talking Tax podcast to talk about proposed gas tax holidays. Gleckman argues that suspending the federal excise tax could actually fuel further price increases, while Dadayan suggests states should instead look at targeted tax rebates to help low-income families struggling with inflation. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The accounting profession offers career options that go beyond working for a CPA firm or corporate finance. George Azih found that his years of working in both arenas built the perfect launch pad to start his own business, and solve some complex financial accounting problems along the way. Azih is the founder and CEO of LeaseQuery, an Atlanta-based company that provides lease accounting software to businesses. In just a decade, Azih turned his startup into a business that Deloitte ranked among the 100 fastest-growing tech companies. On today’s episode of our weekly podcast, Talking Tax, Azih talks with reporter Amanda Iacone about why he got into accounting and his experience as a Black entrepreneur. He also talks about the value of diversity in accounting and of searching for your diversity blind spots. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Courts in Canada have been making high-profile rulings on a key area of corporate tax law in recent years and the federal government could be making even more changes. Transfer pricing—the rules governing how entities within the same corporate group must make transactions as if they were arm’s length—represents a sizable chunk of the money the Canada Revenue Agency collects in tackling aggressive tax avoidance by companies. A court submission by the agency in 2021 said adjustments from transfer pricing over the three previous years increased government revenue by C$11.84 billion ($9.3 billion). But judges have been dismissing the agency’s arguments when companies have decided to fight those adjustments in courts. Two decisions, one dealing with the uranium miner Cameco Corp. and a second with herbicide supplier Agracity Ltd., have grabbed tax practitioners’ attention because of how the courts interpreted Canada’s transfer pricing laws. The federal government has promised a reform of the underlining legislation in light of its courtroom losses, but Ottawa’s options for rewriting the rules are anything but simple. On the latest episode of Talking Tax, David Hogan, partner at Richter LLP, talks about the impact the latest court decisions have had on transfer pricing and where the legal fight could be headed. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Corporations and wealthy taxpayers breathed a sigh of relief when Democrats' economic agenda stalled in the Senate late last year. The roughly $2 trillion package—which the Biden administration branded "Build Back Better"—included a variety of tax hikes, including major changes for pass-through entities. While corporations and high earners may have dodged anticipated tax increases last year, they aren't necessarily off the hook. The legislation remains stalled, but labor and environmental advocates are pushing for President Joe Biden to re-engage with holdout Sen. Joe Manchin (D-W.Va.) in an effort to find a deal. A pair of tax professionals appear on the latest episode of Talking Tax to discuss the Biden administration's stalled tax plans. Laura Zwicker, chair of the Private Client Services Group at Greenberg Glusker, covers how the proposals would effect her high-net-worth clients and what she is advising them to do while the legislation remains in limbo. Then Sarah Brodie, a partner at Morgan Lewis, highlights how partnerships dodged major changes to how they are taxed. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The European Union wants to harmonize how companies issue electronic value-added invoices across the bloc as part of a broader push to make VAT easier to pay. The EU is hoping e-invoicing will help ease complexity and close the gap between expected VAT revenue and what countries actually collected. Lost VAT revenue reached 135 billion euros ($152 billion) in 2019 alone, according to the European Commission. The Commission in January launched a public consultation to explore its role in reducing the administrative burdens of VAT compliance—including harmonizing e-invoicing rules—for businesses and in helping member countries fight VAT fraud. At least 13 EU countries already have, or plan to implement, e-invoicing systems, but variations in rules across the bloc are creating administrative headaches for companies. The deadline for comments is April 15 and the Commission plans a legislative proposal in summer or fall. On the latest episode of Talking Tax, Ellen Cortvriend, director of indirect tax technology at PwC Belgium, talks about what countries are doing on the e-invoicing front, what's ahead for the EU, and what businesses could expect this year. Cortvriend also leads PwC’s global e-invoicing and e-reporting division. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The Biden administration made headlines last year with its plan to provide $80 billion to the IRS to bolster audit and enforcement activities, and tackle the so called “tax gap”—the difference between the amount taxpayers owe and how much they actually pay. It's estimated at $600 billion annually. But what about the states? State revenue departments will face some significant challenges, such as years of chronic underfunding by state legislatures, the loss of experienced auditors, practical limitations resulting from the Covid-19 pandemic, and the growing complexity of state tax codes. To learn about how states are dealing with these state audit and enforcement challenges, we hear from Greg Matson, executive director of the Multistate Tax Commission, and Nancy Prosser, the commission's general counsel. They talk with Bloomberg Tax's Michael J. Bologna about their priorities for this year and why working remotely just isn't as satisfying for tax auditors. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The tax filing season that just kicked off is the third that is being affected by the coronavirus pandemic. Kelly Phillips Erb, Bloomberg Tax editor and host of the Tax Girl podcast, says we haven't yet returned to the way things worked pre-pandemic. In addition to a paper return backlog and understaffed IRS, this year's returns will also be complicated by stimulus checks and advance child tax credit payments. Erb joins our weekly podcast, Talking Tax, to talk about what filers and tax pros can expect in the coming weeks and about why, this year, it may not necessarily be a good idea to file early. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Companies operating in the EU are facing a changing tax landscape in the years ahead, which means they must prepare now to set up systems to report and comply with the new measures. The European Union is targeting 2023 to implement the OECD’s 15% minimum tax. Companies will have to overhaul the way they collect information internally to be able to accurately calculate their effective tax rate for each jurisdiction. In addition, a public country-by-country reporting requirement and possibly another directive targeting shell companies are looming on the horizon. Marlies de Ruiter, global international tax policy leader at EY in the Netherlands, talks about what companies need to focus on now to comply with the coming changes, what important additional information on the minimum tax to watch for from the Organization for Economic Cooperation and Development, and why some companies are already choosing to disclose their tax information before it's required. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Six months into implementation of the new global corporate minimum tax, countries are racing to craft incentives to attract and maintain outside investment. Companies, too, are pouring resources into complying with the tax. The tax took effect in January in dozens of countries across the globe, with a goal of "raising the floor" tax rate to 15% in every country that a multinational company operates in, to reduce profit shifting to low-tax countries. In this podcast episode, Bloomberg Tax reporter Lauren Vella talks through all the ways companies and countries are responding to the new global tax regime, and what new guidance companies can expect in the future. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Kevin Brady, the top Republican on the powerful House Ways and Means Committee, is planning one final legislative push before he retires at the end of this Congress. During the Trump administration, the Texan was instrumental in shepherding the Republican-led 2017 tax law and working across the aisle on a retirement policy overhaul. An outspoken fan of the Houston Astros, Brady has also been a longtime cornerstone for the GOP in the annual Congressional Baseball Game. On the latest episode of our weekly Talking Tax podcast, Brady discusses his impending retirement, the legislation he hopes to advance before he leaves, and his thoughts on how to make the IRS more customer friendly. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Tax preparers are bracing for another frustrating filing season as the IRS warns of unprecedented challenges driven by the pandemic and staffing shortages. The IRS is facing some major issues ahead of the Jan. 24 launch of tax season. The agency entered the new year with millions of unprocessed paper tax returns and has long struggled to keep up with a deluge of phone calls from people and tax pros looking for assistance. National Taxpayer Advocate Erin Collins recently described the agency's telephone service as "the worst it has ever been." The IRS only answered about 11% of the 282 million phone calls it received in fiscal 2021—and those who did get through spent more time than ever on hold. St. Louis-based tax practitioner Jan Roberg is the guest on the latest episode of our weekly Talking Tax podcast. Roberg speaks with Bloomberg Tax reporter Kaustuv Basu about the upcoming tax filing season, offers advice to taxpayers on how to best communicate with the IRS, and shares thoughts on what Congress can do to improve the agency's customer service. Have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690

A severe talent shortage caused by the "Great Resignation" will be the most important issue affecting accounting work in 2022, according to three senior accountants. Labor shortages, along with a loss of institutional knowledge, will cause problems not only at the firms accountants are auditing, but within the accounting firms themselves. Given how widespread this phenomenon is across different sectors, it's a problem that can't necessarily be solved with higher salaries and bonuses. On today's Talking Tax podcast, Bloomberg Tax's Amanda Iacone speaks with three accountants about what they expect will be driving their profession in 2022. In addition to the Great Resignation, they also talk about complying with new sustainability reporting rules and the prospect of new rules coming from the Financial Accounting Standards Board. Have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690

Tax pros are keeping a close eye on Capitol Hill negotiations, with the Internal Revenue Service's 2022 enforcement agenda dependent on how much money Congress gives it to do the job. The Biden administration wants to give the IRS a funding increase for fiscal 2022, plus an additional $80 billion in funding over a decade as part of its stalled tax and social spending package. The goal: give the agency extra resources so it can more aggressively crack down on tax evasion. On today's episode of weekly Talking Tax podcast, two tax enforcement professionals discuss what the new year may have in store at the IRS' enforcement arm. Michelle Levin, a shareholder at Dentons, and Alina Solodchikova, a principal at RSM US, talk about where they think the agency's enforcement targets will be—everything from microcaptive insurance and conservation easements to cryptocurrency. Have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690

Corporate tax departments and accounting firms haven't had much success in diversifying their workforce in recent years, a recent Bloomberg Tax survey shows. The survey data show that while corporate tax departments have seen an increase in the number of female managers over the past four years, overall the tax industry's race and gender demographics still aren't representative of the general population when it comes to high-level jobs. On today’s episode of our weekly podcast, Talking Tax, we speak with Katrina Welch, North America director of tax at Gordon Food Service, and Melinda Phelan, a partner at Baker & McKenzie LLP. Welch and Phelan speak with reporter David Hood about the survey and explain why even when senior leaders are committed to diversity and inclusion, actual change may take time and better strategies. Have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Cryptocurrencies had a big year in 2021, with the asset class drawing in over $2.2 trillion of value. However, these gains have drawn scrutiny from tax authorities. The U.S. in particular has made efforts in recent months to develop rules that would require cryptocurrency exchanges to track the activity of traders to assess their tax compliance. On today’s episode of our weekly podcast, Talking Tax, we hear from Sulolit "Raj" Mukherjee, head of tax for Binance U.S., the largest cryptocurrency exchange in the world. He talks to Bloomberg Tax's Hamza Ali about what the new rules mean for exchanges and the traders that use them. He also discusses the global effort by the OECD to harmonize reporting requirements for crypto exchanges worldwide. Have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Cities and counties have been using so-called "sin taxes" to disincentivize socially harmful behavior for many years. But can this principle be applied to gun violence? A few localities think it can and have passed their own excise taxes on guns and ammunition, even though the legal basis for these taxes may be unclear. One of them, Cook County, Ill., recently had its gun tax struck down by the Illinois Supreme Court as a violation of the constitution’s uniformity clause. The high court never reached a decision on whether Cook County’s tax constituted a direct violation of the right to “keep and bear arms” under the Second Amendment— an issue the plaintiff Guns Save Life still wants the court to answer. On today's episode of our weekly podcast, Talking Tax, we hear two perspectives on this: one from the gun rights attorney who sued Cook County, and another from an economist and gun control advocate. Bloomberg Tax's Michael Bologna spoke to Pete Patterson with the firm Cooper & Kirk about the status of the litigation, and also to Rosanna Smart, a RAND Corporation economist, who supports local gun control measures but questions the value of excise taxes as a strategy for addressing gun violence. Have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690. Everytown for Gun Safety advocates for universal background checks and other gun control measures. Bloomberg Law is operated by entities controlled by Michael Bloomberg, who serves as a member of Everytown for Gun Safety's advisory board.

We're now at the stage where companies, not just individuals, are investing in cryptocurrencies. But that means that accountants have to find a way to quantify crypto's famously volatile price swings on their company's financial statements. There is no specific reference to crypto in U.S. financial accounting rules. But many investors, crypto fans, and even companies themselves want accounting rulemakers to change this—and there are signs the accounting standard-setters may be listening. On this week’s podcast Talking Tax, Bloomberg Tax's Nicola M. White hears from Vivian Fang, accounting professor at the Carlson School of Management at the University of Minnesota. Fang discusses why investors care about the value of companies’ crypto assets and about what future crypto accounting rules might look like. Have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

SPACs—Special Purpose Acquisition Companies or "blank check companies"—became a hot commodity in recent years. The speculative nature and promise of large gains has turned the practice into a major boon for Wall Street—that is, until the SEC announced some rule changes earlier this year that made executing a SPAC a lot more complicated. We have now reached the point where some of the SPACs launched during the boom times now need to be unraveled, creating all kinds of unique tax considerations. On this episode of our weekly podcast, Talking Tax, Jeff Leon speaks with Victor Hollender, a partner at Skadden in New York who has been advising clients on SPAC trends. He spoke about the "de-SPAC" process and where he sees the trend moving next. Have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

A landmark meeting on curbing climate change didn't do much to address the role that tax measures might play, but financial-climate consultants and academics still think they can contribute to reducing greenhouse gas emissions. The COP26 conference agreed on long-awaited rules for global emissions trading markets, one key form of carbon pricing meant to help provide financial incentives for reducing emissions. But carbon taxes—direct levies that increase the price of carbon fuels or the emissions that result from them—weren't dealt with in that agreement. And with the U.S. Congress also not taking action on carbon taxes, some advocates are concerned an opportunity to slow climate change with aggressive policies are falling out of reach. There are still ways taxes could make a difference in the climate arena, however. On this week's episode of Talking Tax, Frank Eich, an economist with U.K. consultancy CRU, spoke to Bloomberg Tax's Michael Rapoport about the COP26 developments and the future of carbon taxes. And Sanjay Patnaik, director of the Brookings Institution's Center on Regulations and Markets, spoke to Bloomberg Tax's David Hood about what's happening in the U.S. Have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Talking Tax is on hiatus for a bit while we create some great new episodes for you. Until then, we're pleased to offer a special presentation of our ABA Silver Gavel award-winning series, UnCommon Law. Generative AI tools are already promising to change the world. Systems like OpenAI's ChatGPT can answer complex questions, write poems and code, and even mimic famous authors with uncanny accuracy. But in using copyrighted materials to train these powerful AI products, are AI companies infringing the rights of untold creators? This season on UnCommon Law, we'll explore the intersection between artificial intelligence and the law. Episode one examines how large language models actually ingest and learn from billions of online data points, including copyrighted works. And we explore the lawsuits filed by creators who claim their copyrights were exploited without permission to feed the data-hungry algorithms powering tools like ChatGPT. If you like this episode and want to hear part 2, visit news.bloomberglaw.com/podcasts, or search for UnCommon Law in your podcast app. Guests: Matthew Butterick, founder at Butterick Law, and co-counsel with the Joseph Saveri Law Firm on class-action lawsuits against OpenAI and others Isaiah Poritz, technology reporter for Bloomberg Law James Grimmelmann, professor of digital and information law at Cornell Tech and Cornell Law School

After years of negotiations led by the Organization for Economic Cooperation and Development, more than 130 jurisdictions backed a deal last month to overhaul how and where multinational companies are taxed. Now countries are gearing up to implement a deal that will reallocate the profits of some of the world's largest companies and set a 15% minimum global tax rate. For the deal to succeed, it will need the support of not just the world's biggest economies but also from developing nations. And that may require politicians in these countries to be willing to nix existing tax treaties with their neighbors that violate the new deal's tenets. That's according to Mary Baine, director of tax projects at the African Tax Administration Forum, an intergovernmental organization that coordinates tax policy across the continent. She spoke to Bloomberg Tax’s Hamza Ali for our weekly podcast Talking Tax about what developing countries countries will need to do to get ready for the new rules over the next two years. Have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Last month saw the resolution of years-long negotiations over a global tax deal. Nearly 140 countries signed an agreement to create a 15% global corporate minimum tax rate and reallocate a portion of the largest multinationals’ profits. But the work doesn’t stop there. Now governments are facing the challenge of implementing the new rules over the next two years—which means deciding on a number of details still left open under both parts of the plan—known as pillars. For multinationals, the implementation of the plan could bring significant change to the global landscape they’re operating in. For this week's episode of our podcast, Talking Tax, Isabel Gottlieb speaks about the international deal with Manal Corwin, the principal in charge of KPMG's Washington National Tax practice. Corwin looks ahead to what’s next for the global plan, how companies may be affected and what they’re doing now to prepare. Have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The growth of so-called "cord cutters" canceling their cable TV subscriptions has had an unintended consequence for local governments: their revenue from the right-of-way fees they impose on the cable companies is drying up. The solution some municipalities have devised for this problem is to levy an equivalent tax on Netflix, Hulu, and the other streaming services that are replacing cable TV in the homes of these cord cutters. On today's episode of Talking Tax, our weekly news podcast, Bloomberg Tax reporter Michael Bologna speaks with an excise tax specialist and a communications law attorney and finds they have very different views on whether imposing local taxes on streamers is a legitimate way to increase public coffers.