Tax Notes Talk – Details, episodes & analysis

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

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

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

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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

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

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

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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

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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

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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

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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

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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.

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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

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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.

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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

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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.

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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

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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.

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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

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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