Demand from clean energy and corporate clients looking to secure their share of credits from the tax-and-climate law is helping boost tax and law firms' footprints.The Biden administration’s 2022 Inflation Reduction Act offers tax incentives to accelerate the US's transition into renewable energy. The tax credits from the law give companies and investors stability for at least the next 10 years."It really put a stamp of approval on these transaction structures and the interest of the administration in exploring and facilitating the growth of renewable energy project development," Alexander Leff, partner at international law firm Clifford Chance, said in an interview.Those looking to benefit from those tax credits are leaning on these firms as the IRS and Treasury Department continue to release guidance on the law's provisions.On this week's episode of Talking Tax, Bloomberg Tax reporters Pavithra Rajesh and Erin Slowey talk with Leff about the wider implications of these clean energy provisions. He also discusses Clifford Chance's recent expansion into Houston—a move the company had planned before the Inflation Reduction Act, but one he called "a natural extension" for the firm's energy portfolio.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Demand from clean energy and corporate clients looking to secure their share of credits from the tax-and-climate law is helping boost tax and law firms' footprints.The Biden administration’s 2022 Inflation Reduction Act offers tax incentives to accelerate the US's transition into renewable energy. The tax credits from the law give companies and investors stability for at least the next 10 years."It really put a stamp of approval on these transaction structures and the interest of the administration in exploring and facilitating the growth of renewable energy project development," Alexander Leff, partner at international law firm Clifford Chance, said in an interview.Those looking to benefit from those tax credits are leaning on these firms as the IRS and Treasury Department continue to release guidance on the law's provisions.On this week's episode of Talking Tax, Bloomberg Tax reporters Pavithra Rajesh and Erin Slowey talk with Leff about the wider implications of these clean energy provisions. He also discusses Clifford Chance's recent expansion into Houston—a move the company had planned before the Inflation Reduction Act, but one he called "a natural extension" for the firm's energy portfolio.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Tax Firms Expand as Clean Energy Credit Demand Grows

The IRS rocked the name, image, and likeness industry after it released a memo saying that many organizations that fund college athletes won't be tax-exempt.The NCAA allows for college athletes and recruits to be compensated for the use of their name, image, and likeness—also known as NIL. NIL collectives were formed, often separate from the university, as a way to help fund and facilitate deals for athletes. Many of these collectives found creative ways, including vying for tax-exempt status, to attract donors.Ayden Syal, CEO and co-founder of MOGL, joins Bloomberg Tax's Erin Slowey on this week's episode of Talking Tax to break down the impact of the recent IRS decision and what it means for his company—a marketplace and software provider for student-athletes, universities, brands, and NIL collectives.Syal also talks about how his company helps college athletes during filing season and how he sees the NIL industry transforming over the next couple of years.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The IRS rocked the name, image, and likeness industry after it released a memo saying that many organizations that fund college athletes won't be tax-exempt.The NCAA allows for college athletes and recruits to be compensated for the use of their name, image, and likeness—also known as NIL. NIL collectives were formed, often separate from the university, as a way to help fund and facilitate deals for athletes. Many of these collectives found creative ways, including vying for tax-exempt status, to attract donors.Ayden Syal, CEO and co-founder of MOGL, joins Bloomberg Tax's Erin Slowey on this week's episode of Talking Tax to break down the impact of the recent IRS decision and what it means for his company—a marketplace and software provider for student-athletes, universities, brands, and NIL collectives.Syal also talks about how his company helps college athletes during filing season and how he sees the NIL industry transforming over the next couple of years.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

IRS Cracks Down on NIL Collectives' Tax-Exempt Status

Governments landed agreement on some of the global tax deal's biggest open issues earlier this month. But major political questions remain.The issues will play out over the coming years in the US and around the world, said Bob Stack, who was the Treasury Department's OECD tax negotiator under the Obama administration and is now a managing director at Deloitte.In a conversation with Bloomberg Tax's Isabel Gottlieb, Stack talked about the recent agreement by the negotiating governments that will shield US companies' US income from foreign minimum tax for an extra year, and what that means for future global tax legislation in the US Congress.Stack also talked about prospects for the agreed, conditional freeze on new digital services taxes during remaining negotiations over implementation of Amount A, the global deal's profit reallocation plan.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Governments landed agreement on some of the global tax deal's biggest open issues earlier this month. But major political questions remain.The issues will play out over the coming years in the US and around the world, said Bob Stack, who was the Treasury Department's OECD tax negotiator under the Obama administration and is now a managing director at Deloitte.In a conversation with Bloomberg Tax's Isabel Gottlieb, Stack talked about the recent agreement by the negotiating governments that will shield US companies' US income from foreign minimum tax for an extra year, and what that means for future global tax legislation in the US Congress.Stack also talked about prospects for the agreed, conditional freeze on new digital services taxes during remaining negotiations over implementation of Amount A, the global deal's profit reallocation plan.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The Politics of the Global Tax Deal, and What's Next

The US Senate passed a long-stalled tax treaty with Chile last month, overcoming a dispute between Republicans and the Treasury Department over treatment of foreign tax credits.Business groups had been pushing for the measure to strengthen economic ties with the South American country and to allow companies to avoid double taxation. Chile is one of the biggest producers of lithium, a key element in batteries and other technology.On this week’s episode of Talking Tax, Bloomberg Tax reporter Chris Cioffi talks with Business Roundtable Vice President for Tax and Fiscal Policy Catherine Schultz about a range of topics, including the Chile tax treaty and the fate of other treaties pending in the Senate. They also discuss Republican concerns that emerged in this Congress over double taxation and how lawmakers resolved the issue, at least temporarily, in the treaty.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The US Senate passed a long-stalled tax treaty with Chile last month, overcoming a dispute between Republicans and the Treasury Department over treatment of foreign tax credits.Business groups had been pushing for the measure to strengthen economic ties with the South American country and to allow companies to avoid double taxation. Chile is one of the biggest producers of lithium, a key element in batteries and other technology.On this week’s episode of Talking Tax, Bloomberg Tax reporter Chris Cioffi talks with Business Roundtable Vice President for Tax and Fiscal Policy Catherine Schultz about a range of topics, including the Chile tax treaty and the fate of other treaties pending in the Senate. They also discuss Republican concerns that emerged in this Congress over double taxation and how lawmakers resolved the issue, at least temporarily, in the treaty.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Business Roundtable Official Talks Chile Tax Treaty

Unverified claims that the IRS plans to hire a horde of weapon-carrying agents are putting agency employees at risk, said Tony Reardon, longtime leader of the National Treasury Employees Union."It places them squarely in danger," Reardon said, referring to charges from Republican politicians that thousands of armed agents would soon be probing Americans’ finances as a result of tax-and-climate law funds.Reardon, who's worked at NTEU for more than three decades and was first elected national union president in 2015, is set to retire in August. NTEU represents about 65,000 IRS employees as well as workers at dozens of other departments and agencies.On this week's episode of Talking Tax, he talks with Bloomberg Tax reporter Naomi Jagoda about a range of topics, including how things have changed for IRS employees over the years and how the IRS can improve recruitment and retention.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Unverified claims that the IRS plans to hire a horde of weapon-carrying agents are putting agency employees at risk, said Tony Reardon, longtime leader of the National Treasury Employees Union."It places them squarely in danger," Reardon said, referring to charges from Republican politicians that thousands of armed agents would soon be probing Americans’ finances as a result of tax-and-climate law funds.Reardon, who's worked at NTEU for more than three decades and was first elected national union president in 2015, is set to retire in August. NTEU represents about 65,000 IRS employees as well as workers at dozens of other departments and agencies.On this week's episode of Talking Tax, he talks with Bloomberg Tax reporter Naomi Jagoda about a range of topics, including how things have changed for IRS employees over the years and how the IRS can improve recruitment and retention.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Treasury Union Retiring Chief Talks IRS Worker Safety

The IRS has sounded the alarm multiple times over the past year about widespread scams associated with the employee retention credit—a pandemic-era tax incentive meant to encourage businesses to retain their employees during the worst of the Covid-19 crisis.Still, advertisements by third-party bad actors promoting the credit persisted, and faulty employee retention credit claims became so prevalent that in March, the IRS put the employee retention credit on its "Dirty Dozen" list of scams.The issue of false or incorrectly claimed credits has begun to bleed into the world of mergers and acquisitions, prolonging deals and creating more hours of due diligence work.On this week's episode of Talking Tax, Bloomberg Tax reporter Lauren Vella sits down with Jenn McCabe, a partner at Armanino LLP, to hear about the fallout from what was meant as a pandemic rescue plan.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The IRS has sounded the alarm multiple times over the past year about widespread scams associated with the employee retention credit—a pandemic-era tax incentive meant to encourage businesses to retain their employees during the worst of the Covid-19 crisis.Still, advertisements by third-party bad actors promoting the credit persisted, and faulty employee retention credit claims became so prevalent that in March, the IRS put the employee retention credit on its "Dirty Dozen" list of scams.The issue of false or incorrectly claimed credits has begun to bleed into the world of mergers and acquisitions, prolonging deals and creating more hours of due diligence work.On this week's episode of Talking Tax, Bloomberg Tax reporter Lauren Vella sits down with Jenn McCabe, a partner at Armanino LLP, to hear about the fallout from what was meant as a pandemic rescue plan.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Employee Retention Credit a Due Diligence Snag for M&A

Small family vineyards throughout France face an uncertain future as the cost to transfer estates within a family climb under a complicated system of inheritance taxation and rising property values from sales to foreign or institutional investors.The costs can be so great that some can’t pay the inheritance tax without running up long-term debt or selling off a portion of their estate. French lawmakers are considering ways to help reduce the tax burden for family vineyards, which number just 7,000 today.On this week’s episode of our podcast, Talking Tax, Bloomberg Tax correspondent Shaun Courtney talks about her reporting into the inheritance tax challenges facing France's small family-owned vineyards. She traveled to Champagne to visit a vineyard owned by Sophie Moussié, the fifth generation in her family to run the estate.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Small family vineyards throughout France face an uncertain future as the cost to transfer estates within a family climb under a complicated system of inheritance taxation and rising property values from sales to foreign or institutional investors.The costs can be so great that some can’t pay the inheritance tax without running up long-term debt or selling off a portion of their estate. French lawmakers are considering ways to help reduce the tax burden for family vineyards, which number just 7,000 today.On this week’s episode of our podcast, Talking Tax, Bloomberg Tax correspondent Shaun Courtney talks about her reporting into the inheritance tax challenges facing France's small family-owned vineyards. She traveled to Champagne to visit a vineyard owned by Sophie Moussié, the fifth generation in her family to run the estate.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Family Vineyards Grapple With French Inheritance Taxes

Most of the banks that failed or came close to it this spring had one thing in common: They had recently received a clean bill of health from their auditor, KPMG.This development has caused major problems for the Big Four auditing firm and has shareholders, regulators, and even lawmakers asking KPMG tough questions.On this week's episode of our podcast, Talking Tax, Bloomberg Tax reporter Amanda Iacone talks about her reporting into KPMG's troubles and why this newest accounting scandal, just one of many over the past two decades, has stirred up concern for many in the profession.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Most of the banks that failed or came close to it this spring had one thing in common: They had recently received a clean bill of health from their auditor, KPMG.This development has caused major problems for the Big Four auditing firm and has shareholders, regulators, and even lawmakers asking KPMG tough questions.On this week's episode of our podcast, Talking Tax, Bloomberg Tax reporter Amanda Iacone talks about her reporting into KPMG's troubles and why this newest accounting scandal, just one of many over the past two decades, has stirred up concern for many in the profession.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

KPMG's Bank Audit Troubles Give Accounting a Black Eye

The OECD's global tax deal is approaching a milestone: The organization expects to see the release this summer of major remaining pieces of the agreement that have been under negotiation.But throughout the process, many developing countries have felt their concerns weren't sufficiently addressed, said Marlene Nembhard-Parker, a senior tax official in Jamaica who is also co-chair of the Inclusive Framework of 143 countries working on the global tax agreement.Meanwhile, the United Nations also has a new international tax effort in the works. That project isn't intended to duplicate or undermine the OECD's work, she said, but to "address the issues of legitimacy as to who is responsible for setting global tax rules."On this week's Talking Tax, Nembhard-Parker speaks about developing countries' perspective on the agenda and outcomes of the OECD and UN work, and why the commitment from governments to reach agreement on Pillar One creates a sense of "cautious optimism."Nembhard-Parker's remarks are part of a pre-recorded interview aired during the Bloomberg Tax Leadership Forum, held virtually Tuesday. 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 global tax deal is approaching a milestone: The organization expects to see the release this summer of major remaining pieces of the agreement that have been under negotiation.But throughout the process, many developing countries have felt their concerns weren't sufficiently addressed, said Marlene Nembhard-Parker, a senior tax official in Jamaica who is also co-chair of the Inclusive Framework of 143 countries working on the global tax agreement.Meanwhile, the United Nations also has a new international tax effort in the works. That project isn't intended to duplicate or undermine the OECD's work, she said, but to "address the issues of legitimacy as to who is responsible for setting global tax rules."On this week's Talking Tax, Nembhard-Parker speaks about developing countries' perspective on the agenda and outcomes of the OECD and UN work, and why the commitment from governments to reach agreement on Pillar One creates a sense of "cautious optimism."Nembhard-Parker's remarks are part of a pre-recorded interview aired during the Bloomberg Tax Leadership Forum, held virtually Tuesday. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Developing Countries Want Voices Heard on Global Tax

Minnesota lawmakers just finished a historic legislative session that achieved something rarely seen in the state tax arena—a budget featuring both the biggest tax cut and the biggest tax hike in state history. The resulting tax overhaul measure includes $3 billion in tax relief from one-time refunds, tax credits, and a tax waiver on most Social Security income. But it also raises $1 billion through a tax on the earnings of foreign subsidiaries of multinational corporations and a new levy on individuals with investment income over $1 million.The state's lawmakers also made headlines for first passing and then rescinding a plan to calculate corporations' state income taxes on the basis of their worldwide income. The controversial plan would have made Minnesota the only state to abandon “water’s edge” rules, which permit businesses to exclude foreign affiliates’ income when they file their state income tax returns.On this episode of Talking Tax, Bloomberg Tax senior reporter Michael J. Bologna discusses this consequential legislative session with Rep. Aisha Gomez (D), chair of the House Taxes Committee. Gomez, a progressive in her third term, discusses the practical, political, and personal challenges she had to overcome in delivering the tax package.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Minnesota lawmakers just finished a historic legislative session that achieved something rarely seen in the state tax arena—a budget featuring both the biggest tax cut and the biggest tax hike in state history. The resulting tax overhaul measure includes $3 billion in tax relief from one-time refunds, tax credits, and a tax waiver on most Social Security income. But it also raises $1 billion through a tax on the earnings of foreign subsidiaries of multinational corporations and a new levy on individuals with investment income over $1 million.The state's lawmakers also made headlines for first passing and then rescinding a plan to calculate corporations' state income taxes on the basis of their worldwide income. The controversial plan would have made Minnesota the only state to abandon “water’s edge” rules, which permit businesses to exclude foreign affiliates’ income when they file their state income tax returns.On this episode of Talking Tax, Bloomberg Tax senior reporter Michael J. Bologna discusses this consequential legislative session with Rep. Aisha Gomez (D), chair of the House Taxes Committee. Gomez, a progressive in her third term, discusses the practical, political, and personal challenges she had to overcome in delivering the tax package.Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Key Minnesota Lawmaker on Tackling Corporate Taxes

Talking Tax, from Bloomberg Tax, is a weekly discussion of the most pressing issues facing tax and accounting professionals. Each week the podcast features discussions with lawmakers, federal regulators, lawyers, and journalists. From the courts to Capitol Hill to the IRS, Talking Tax has it covered.

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Just discovered this show, and am looking forward to hearing new episodes.

Fantastic podcast

Talking Tax

Marc Bekerman joins Andrea L. Ben-Yosef in a two-part podcast about post-mortem estate planning. Marc is a solo practitioner in Long Island, New York, and an adjunct professor of law at New York Law School where he formerly served as the Associate Director of its Graduate Tax Program.  Marc is also a member of the Estates Gifts and Trusts Advisory Board for Bloomberg BNA. It may be surprising to know that the death of a person does not end the ability to refine their estate plan. Marc discusses how estate planners can still take actions after a person’s death to maximize the benefit to the beneficiaries. Part 1 covers estate tax considerations, such as whether to elect alternate valuation of assets and where and when to deduct administration expenses. Part 2 will cover income tax planning opportunities.

Marc Bekerman joins Andrea L. Ben-Yosef in a two-part podcast about post-mortem estate planning. Marc is a solo practitioner in Long Island, New York, and an adjunct professor of law at New York Law School where he formerly served as the Associate Director of its Graduate Tax Program. Marc is also a member of the Estates Gifts and Trusts Advisory Board for Bloomberg BNA. It may be surprising to know that the death of a person does not end the ability to refine their estate plan. Marc discusses how estate planners can still take actions after a person’s death to maximize the benefit to the beneficiaries. Part 1 covers estate tax considerations, such as whether to elect alternate valuation of assets and where and when to deduct administration expenses. Part 2 will cover income tax planning opportunities.

Fine Tuning an Estate Plan After Death (Part 1)

The U.S. Supreme Court’s 2018 South Dakota v. Wayfair decision upended a 26-year precedent that limited a state’s authority to tax goods being sold across state lines. A year later, states have amended their laws to target remote sellers and online sales platforms like Amazon.com Inc. Bloomberg Tax reporter Ryan Prete spoke with Diane Yetter, founder of the Sales Tax Institute and president of consulting firm Yetter Tax, to discuss the ruling’s legacy so far and possible future legal issues. She said legal challenges could begin with differing interpretations of the laws, and go as far as class-action lawsuits against sellers for not collecting the taxes appropriately.  Listen and subscribe to Talking Tax from your mobile device: Via Apple Podcasts | Via Stitcher | Via Overcast | Via Spotify

The U.S. Supreme Court’s 2018 <a href="https://www.bloomberglaw.com/public/desktop/document/South_Dakota_v_Wayfair_Inc_No_17494_2018_BL_219995_US_June_21_201?1542221358" rel="nofollow" target="_blank">South Dakota v. Wayfair</a> decision upended a 26-year precedent that limited a state’s authority to tax goods being sold across state lines. A year later, states have amended their laws to target remote sellers and online sales platforms like <a href="http://Amazon.com" rel="nofollow" target="_blank">Amazon.com</a> Inc. Bloomberg Tax reporter Ryan Prete spoke with Diane Yetter, founder of the Sales Tax Institute and president of consulting firm Yetter Tax, to discuss the ruling’s legacy so far and possible future legal issues. She said legal challenges could begin with differing interpretations of the laws, and go as far as class-action lawsuits against sellers for not collecting the taxes appropriately.  Listen and subscribe to Talking Tax from your mobile device: <a href="https://podcasts.apple.com/us/podcast/talking-tax/id1247619396" rel="nofollow" target="_blank">Via Apple Podcasts</a> | <a href="https://www.stitcher.com/podcast/bloomberg-bna-3/talking-tax" rel="nofollow" target="_blank">Via Stitcher</a> | <a href="https://overcast.fm/itunes1247619396/talking-tax" rel="nofollow" target="_blank">Via Overcast</a> | <a href="https://open.spotify.com/show/3Wr9WlSuJE5XWydOzBaO04" rel="nofollow" target="_blank">Via Spotify</a>

Buying Online? ‘Wayfair’ Tax Is Straining E-Commerce

Congressional steering committees have tapped lawmakers to join the tax-writing panels in the House and Senate, and those new additions are starting to set priorities.Bloomberg Tax’s Lydia O’Neal and Kaustuv Basu join host Amanda Iacone to discuss the news in Congress while negotiations to end the partial government shutdown have stalled.New Senate Finance Committee Chairman Chuck Grassley (R-Iowa) has announced his intent to look into what authority he has to access President Donald Trump’s tax returns, though it is unclear whether he wants to release them or counter efforts by House Ways and Means Committee Chairman Richard Neal (D-Mass.).Neal’s committee added new members, including six members of the Progressive Caucus who could shift the panel’s agenda leftward.Host: Amanda Iacone.Producer: Nicholas Anzalotta-Kynoch.

Congressional steering committees have tapped lawmakers to join the tax-writing panels in the House and Senate, and those new additions are starting to set priorities. Bloomberg Tax’s Lydia O’Neal and Kaustuv Basu join host Amanda Iacone to discuss the news in Congress while negotiations to end the partial government shutdown have stalled. New Senate Finance Committee Chairman Chuck Grassley (R-Iowa) has announced his intent to look into what authority he has to access President Donald Trump’s tax returns, though it is unclear whether he wants to release them or counter efforts by House Ways and Means Committee Chairman Richard Neal (D-Mass.). Neal’s committee added new members, including six members of the Progressive Caucus who could shift the panel’s agenda leftward. Host: Amanda Iacone. Producer: Nicholas Anzalotta-Kynoch.

Tax Writers Begin to Chart Course in New Congress

Congress now has a host of smaller tax issues to contend with after passing legislation overhauling many aspects of the Internal Revenue Code.The Republican-led House Ways and Means and Senate Finance committees are looking at ways to make corrections to, and address issues omitted from, the new tax law (Pub. L. No. 115-97). Tax writers will consider overhauling the Internal Revenue Service, streamlining tax-favored savings accounts for education and retirement, and passing legislation to extend some expired tax breaks.These goals will face headwinds now that tax isn't the No. 1 agenda item in Congress. Politics, negotiations over funding the government, and competing policy priorities could all waylay the tax writers' plans.Reporters Kaustuv Basu, Allyson Versprille, and Laura Davison spoke with Talking Tax host Matthew Beddingfield on Jan. 22 about what’s next for lawmakers in 2018.

Congress now has a host of smaller tax issues to contend with after passing legislation overhauling many aspects of the Internal Revenue Code. The Republican-led House Ways and Means and Senate Finance committees are looking at ways to make corrections to, and address issues omitted from, the new tax law (Pub. L. No. 115-97). Tax writers will consider overhauling the Internal Revenue Service, streamlining tax-favored savings accounts for education and retirement, and passing legislation to extend some expired tax breaks. These goals will face headwinds now that tax isn't the No. 1 agenda item in Congress. Politics, negotiations over funding the government, and competing policy priorities could all waylay the tax writers' plans. Reporters Kaustuv Basu, Allyson Versprille, and Laura Davison spoke with Talking Tax host Matthew Beddingfield on Jan. 22 about what’s next for lawmakers in 2018.

Hill Roundtable- Episode 56- Federal Tax Priorities for the Coming Year

It's not every day the U.S. Supreme Court agrees to take on a tax case.The Supreme Court on March 21 decided a major tax case dealing with the obstruction of an IRS investigation when it ruled in Marinello v. United States that the Internal Revenue Service can only convict a taxpayer on obstruction charges when it can prove the taxpayer was aware of a pending tax-related proceeding, such as an investigation or audit, or that the taxpayer could "reasonably foresee that such a proceeding would commence."Another significant tax case, Wisconsin Central Ltd v. United States, currently being reviewed by the high court,  involves the taxation of stock given to employees by a railroad company. The Supreme Court is scheduled to hear oral arguments on April 16.Bloomberg Tax's Carolina Vargas talked to practitioners to discuss the cases and their significance.

It's not every day the U.S. Supreme Court agrees to take on a tax case. The Supreme Court on March 21 decided a major tax case dealing with the obstruction of an IRS investigation when it ruled in Marinello v. United States that the Internal Revenue Service can only convict a taxpayer on obstruction charges when it can prove the taxpayer was aware of a pending tax-related proceeding, such as an investigation or audit, or that the taxpayer could "reasonably foresee that such a proceeding would commence." Another significant tax case, Wisconsin Central Ltd v. United States, currently being reviewed by the high court, involves the taxation of stock given to employees by a railroad company. The Supreme Court is scheduled to hear oral arguments on April 16. Bloomberg Tax's Carolina Vargas talked to practitioners to discuss the cases and their significance.

Talking Tax- Episode 61- Tax Cases at the Supreme Court

David Kautter

David Kautter, assistant Treasury secretary for tax policy, discussed international digital tax issues, regulations stemming from the 2017 tax law, and more in an exclusive interview at the Bloomberg Tax Leadership Forum Nov. 19.Background reading:  The Treasury Department is planning to issue regulations restricting how hedge fund managers can claim a valuable tax break by early next year. IRS Office Carrying Out 2017 Tax Law No Longer Exists: Kautter 

David Kautter, assistant Treasury secretary for tax policy, discussed international digital tax issues, regulations stemming from the 2017 tax law, and more in an exclusive interview at the Bloomberg Tax Leadership Forum Nov. 19. Background reading: <ul> <li>The Treasury Department is planning to <a href="https://news.bloombergtax.com/daily-tax-report/carried-interest-tax-rules-slated-for-2020-official-says?utm_source=podcast&amp;utm_medium=taxdesk&amp;utm_campaign=taxpodtest1" rel="nofollow" target="_blank">issue regulations</a> restricting how hedge fund managers can claim a valuable tax break by early next year.</li> <li><a href="https://news.bloombergtax.com/daily-tax-report/irs-office-carrying-out-2017-tax-law-no-longer-exists-kautter-1?utm_source=podcast&amp;utm_medium=taxdesk&amp;utm_campaign=taxpodtest1" rel="nofollow" target="_blank">IRS Office Carrying Out 2017 Tax Law No Longer Exists: Kautter</a></li> </ul>

U.S. Treasury Tax Policy: A Talk With David Kautter

The Center for Audit Quality is working on a quality indicator framework that could be used to compare accounting firms' performance. Setting quality metrics has long been discussed but until recently hadn't gained traction in the U.S. audit market. The center plans to issue its tool in early 2019. Cindy Fornelli, executive director of the Center for Audit Quality, spoke with Bloomberg Tax’s Amanda Iacone about why audit quality indicators are getting so much attention lately. She also discussed how camaraderie and diversity among the members of the Public Company Accounting Oversight Board could lead to better audit oversight, and the role U.S. regulators play in the ongoing audit debate in the UK.

The Center for Audit Quality is working on a quality indicator framework that could be used to compare accounting firms' performance. Setting quality metrics has long been discussed but until recently hadn't gained traction in the U.S. audit market. The center plans to issue its tool in early 2019. Cindy Fornelli, executive director of the Center for Audit Quality, spoke with Bloomberg Tax’s Amanda Iacone about why audit quality indicators are getting so much attention lately. She also discussed how camaraderie and diversity among the members of the Public Company Accounting Oversight Board could lead to better audit oversight, and the role U.S. regulators play in the ongoing audit debate in the UK.

CAQ’s Fornelli on Audit Oversight, Trends, U.K. Debate

Michael Desmond became the Internal Revenue Service’s chief counsel earlier this year as the agency was well into implementing the complex 2017 tax code overhaul.In a wide-ranging conversation with senior editor Colleen Murphy June 27 at the Bloomberg Tax Leadership Forum in New York, Desmond expressed encouragement at the hiring of “energized attorneys” to implement the law.He recommended that companies pay attention to interrelationships among various provisions, especially in the international arena. He talked about non-tax overhaul priorities, too—including strengthening partnership audits and figuring out long-term streamlining of controversies over syndicated conservation easements.Listen to their conversation—plus a bit of Q&amp;A with the forum audience—on a special episode of Talking Tax.

Michael Desmond became the Internal Revenue Service’s chief counsel earlier this year as the agency was well into implementing the complex 2017 tax code overhaul.In a wide-ranging conversation with senior editor Colleen Murphy June 27 at the Bloomberg Tax Leadership Forum in New York, Desmond expressed encouragement at the hiring of “energized attorneys” to implement the law.He recommended that companies pay attention to interrelationships among various provisions, especially in the international arena. He talked about non-tax overhaul priorities, too—including strengthening partnership audits and figuring out long-term streamlining of controversies over syndicated conservation easements.Listen to their conversation—plus a bit of Q&amp;A with the forum audience—on a special episode of Talking Tax.

IRS Top Attorney Names Priorities Post-2017 Tax Law

Kate Barton

Kate Barton has been navigating unprecedented change in tax systems around the planet since becoming EY’s global vice chair for tax and legal services in early 2018.Trade wars and Brexit are roiling markets and expectations, and countries are scrambling for their share of corporate revenue while trying to transform their tax regimes for the digital-commerce age.The OECD aims for consensus by 2020 in its project on tax system modernization, but as Barton points out, “these are in fact guidelines, and then 140 countries have to read these and then legislate their own country legislation.” Interesting, she says, especially “in a world right now where we seem to be a little more nationalistic.”Talking Tax host Amanda Iacone talked with Barton about all of that and more, including EY’s legal managed services business and diversity.

Kate Barton has been navigating unprecedented change in tax systems around the planet since becoming EY’s global vice chair for tax and legal services in early 2018.Trade wars and Brexit are roiling markets and expectations, and countries are scrambling for their share of corporate revenue while trying to transform their tax regimes for the digital-commerce age.The OECD aims for consensus by 2020 in its project on tax system modernization, but as Barton points out, “these are in fact guidelines, and then 140 countries have to read these and then legislate their own country legislation.” Interesting, she says, especially “in a world right now where we seem to be a little more nationalistic.”Talking Tax host Amanda Iacone talked with Barton about all of that and more, including EY’s legal managed services business and diversity.

The View From a Global Tax Chief: EY’s Kate Barton 

In the third and final episode of The Over/Under, Richard Auxier of the Tax Policy Center gives Bloomberg Tax’s Ryan Prete a 2019 outlook. Next, Ryan discusses a newly released federal sports betting framework.Ryan then takes a look at betting totals from 2018 and gets a 2019 sports betting prediction from Ted Leonsis, owner of the NBA’s Washington Wizards and Stanley Cup Champion Washington Capitals.Host: Ryan Prete.Producer: Nicholas Anzalotta-Kynoch.

In the third and final episode of The Over/Under, Richard Auxier of the Tax Policy Center gives Bloomberg Tax’s Ryan Prete a 2019 outlook. Next, Ryan discusses a newly released federal sports betting framework. Ryan then takes a look at betting totals from 2018 and gets a 2019 sports betting prediction from Ted Leonsis, owner of the NBA’s Washington Wizards and Stanley Cup Champion Washington Capitals. Host: Ryan Prete. Producer: Nicholas Anzalotta-Kynoch.

The Over/Under: Sports Betting in 2019

When Congress put a $10,000 cap on the amount of state and local taxes individuals can deduct from their federal income taxes, high-tax states tried to fight for their residents in a couple of different ways.One way—charitable funds that earned people state tax credits for donations—got shot down by the IRS.But states have tried another kind of workaround. Because the deduction cap applies only to individuals, not to businesses, some states have instituted new taxes on pass-through businesses, like LLCs and partnerships. These entities normally don’t pay taxes. Instead, their individual owners pay tax on the business income.Bloomberg Tax team lead Jeff Harrington explored the state workarounds with Cannon-Marie Green, the managing editor overseeing Bloomberg Tax’s editorial coverage of state corporate income tax and pass-throughs.Listen and subscribe to Talking Tax from your mobile device: Via Apple Podcasts | Via Stitcher | Via Overcast | Via Spotify

When Congress put a $10,000 cap on the amount of state and local taxes individuals can deduct from their federal income taxes, high-tax states tried to fight for their residents in a couple of different ways.One way—charitable funds that earned people state tax credits for donations—got shot down by the IRS.But states have tried another kind of workaround. Because the deduction cap applies only to individuals, not to businesses, some states have instituted new taxes on pass-through businesses, like LLCs and partnerships. These entities normally don’t pay taxes. Instead, their individual owners pay tax on the business income.Bloomberg Tax team lead Jeff Harrington explored the state workarounds with Cannon-Marie Green, the managing editor overseeing Bloomberg Tax’s editorial coverage of state corporate income tax and pass-throughs.Listen and subscribe to Talking Tax from your mobile device: <a href="https://podcasts.apple.com/us/podcast/talking-tax/id1247619396" rel="nofollow" target="_blank">Via Apple Podcasts</a> | <a href="https://www.stitcher.com/podcast/bloomberg-bna-3/talking-tax" rel="nofollow" target="_blank">Via Stitcher</a> | <a href="https://overcast.fm/itunes1247619396/talking-tax" rel="nofollow" target="_blank">Via Overcast</a> | <a href="https://open.spotify.com/show/3Wr9WlSuJE5XWydOzBaO04" rel="nofollow" target="_blank">Via Spotify</a>

SALT Cap Workarounds: States Try Pass-Through Taxes

The federal tax on a category of income called GILTI—global intangible low-taxed income—has state-level implications for multinational businesses.Congress created GILTI to stop companies from shifting profits abroad through intangible assets—royalties, patents, and the like. When a company’s total overseas income has been taxed abroad at less than a certain rate, the U.S. applies a tax.In the U.S., state governments often conform their own tax laws to the federal tax code. But with GILTI, states are all over the map. For most states it means a very modest increase in their corporate tax base, but for companies it can mean dealing with multiple approaches and calculations. And there’s talk of legal challenges.Talking Tax host Siri Bulusu talked about GILTI with Bruce Fort, counsel to the Multistate Tax Commission, who has an eagle’s-eye view of what the states are doing. They spoke at the American Bar Association tax section’s fall meeting in San Francisco.

The federal tax on a category of income called GILTI—global intangible low-taxed income—has state-level implications for multinational businesses.Congress created GILTI to stop companies from shifting profits abroad through intangible assets—royalties, patents, and the like. When a company’s total overseas income has been taxed abroad at less than a certain rate, the U.S. applies a tax.In the U.S., state governments often conform their own tax laws to the federal tax code. But with GILTI, states are all over the map. For most states it means a very modest increase in their corporate tax base, but for companies it can mean dealing with multiple approaches and calculations. And there’s talk of legal challenges.Talking Tax host Siri Bulusu talked about GILTI with Bruce Fort, counsel to the Multistate Tax Commission, who has an eagle’s-eye view of what the states are doing. They spoke at the American Bar Association tax section’s fall meeting in San Francisco.

How Are States Taxing the Income Called GILTI?

Kate Kraus joins Andrea L. Ben-Yosef to talk about the partnership audit regulations. Kate recently joined Allen Matkins as a tax partner in the firm’s Los Angeles office. There have been several rounds of proposed, temporary, and final regulations, with the most recent ones issued in August. Kate discusses some key issues to take into account under the new guidance, such as what happens if the partnership representative leaves, taking favorable adjustments into account, and other issues that tax practitioners are dealing with.

Kate Kraus joins Andrea L. Ben-Yosef to talk about the partnership audit regulations. Kate recently joined Allen Matkins as a tax partner in the firm’s Los Angeles office. There have been several rounds of proposed, temporary, and final regulations, with the most recent ones issued in August. Kate discusses some key issues to take into account under the new guidance, such as what happens if the partnership representative leaves, taking favorable adjustments into account, and other issues that tax practitioners are dealing with.

Partnership Audit Regulations: Where Do We Stand Now? (Part I)

Many people are now working and living away from their usual homes or offices, either by choice or otherwise, as they wait out the spread of the coronavirus.In which jurisdiction do these people pay taxes?On this episode of Talking Tax, reporters Isabel Gottlieb and Siri Bulusu look at why this is a huge headache not just for taxpayers but also for their employers, who may have to start withholding in states they've never withheld in before. They also talk about the even more complicated issue of people who are working remotely from another country.

Many people are now working and living away from their usual homes or offices, either by choice or otherwise, as they wait out the spread of the coronavirus. In which jurisdiction do these people pay taxes? On this episode of <a href="https://news.bloomberglaw.com/podcasts/talking-tax" rel="nofollow" target="_blank">Talking Tax</a>, reporters <a href="https://twitter.com/IsabelGottlieb" rel="nofollow" target="_blank">Isabel Gottlieb</a> and <a href="https://twitter.com/siri_notsiri" rel="nofollow" target="_blank">Siri Bulusu</a> look at why this is a huge headache not just for taxpayers but also for their employers, who may have to start withholding in states they've never withheld in before. They also talk about the even more complicated issue of people who are working remotely from another country.

How Pandemic Vacations Can Turn Into Tax Nightmares

Talking Tax embarks on the 2020s with a lively conversation about how tax policy evolved through the 2010s.Bloomberg Tax law analyst Mary Gillmarten, a veteran of government and private-practice work, reviews the decade’s major developments—especially how the U.S. and other countries started tackling globalization and the digitalized economy. And she has thoughts about implications for our future.

Talking Tax embarks on the 2020s with a lively conversation about how tax policy evolved through the 2010s.Bloomberg Tax law analyst Mary Gillmarten, a veteran of government and private-practice work, reviews the decade’s major developments—especially how the U.S. and other countries started tackling globalization and the digitalized economy. And she has thoughts about implications for our future.

The Tax Decade: How the 2010s Led to Where We Are Now

Some of the biggest investment funds—Ares Management Corp., KKR &amp; Co. Inc., and others—converted from partnerships to C corporations after Congress slashed the corporate tax rate in the 2017 tax law. But conversions aren’t for everyone, not by a long shot.Jeremy Swan, managing principal at CohnReznick in New York, talks about the pros and cons, the questions that businesses should ask themselves, and the political uncertainties right now that signal the wisdom of a “wait and see” approach to further conversions.

Some of the biggest investment funds—Ares Management Corp., KKR &amp; Co. Inc., and others—converted from partnerships to C corporations after Congress slashed the corporate tax rate in the 2017 tax law. But conversions aren’t for everyone, not by a long shot.Jeremy Swan, managing principal at CohnReznick in New York, talks about the pros and cons, the questions that businesses should ask themselves, and the political uncertainties right now that signal the wisdom of a “wait and see” approach to further conversions.

Converting to a C Corporation: Things to Think About 

The Organization for Economic Cooperation and Development is going into 2020 with some of its most complex work ever: shepherding efforts for a global rewrite of corporate taxation systems in the digital economy.Host Siri Bulusu spoke with Bloomberg Tax reporter Isabel Gottlieb about issues the OECD is facing and implications for countries and companies.

The Organization for Economic Cooperation and Development is going into 2020 with some of its most complex work ever: shepherding efforts for a global rewrite of corporate taxation systems in the digital economy.Host Siri Bulusu spoke with Bloomberg Tax reporter Isabel Gottlieb about issues the OECD is facing and implications for countries and companies.

The OECD and Taxes for the Digital Economy: a Primer

Michael Hadley and Adam McMahon of Davis &amp; Harman join Andrea L. Ben-Yosef to talk about the key provisions in the Family Savings Act, how it was influenced by RESA, and its prospects for enactment after the mid-term elections. With the Congress racing to stop a government shutdown, does Congress have the attention span to focus on bipartisan retirement plan reforms?For more information, see their Daily Tax Report Insight: Are We on the Verge of the Next Big Pension Bill? A Review of the House-Passed Family Savings Act.

Michael Hadley and Adam McMahon of Davis &amp; Harman join Andrea L. Ben-Yosef to talk about the key provisions in the Family Savings Act, how it was influenced by RESA, and its prospects for enactment after the mid-term elections. With the Congress racing to stop a government shutdown, does Congress have the attention span to focus on bipartisan retirement plan reforms? For more information, see their Daily Tax Report Insight: Are We on the Verge of the Next Big Pension Bill? A Review of the House-Passed Family Savings Act.

Retirement Plan Provisions That Could Finally Make Their Way Through Congress

Opportunity zones and opportunity funds were created by the 2017 tax act to encourage business investment in low-income communities. They have attracted a lot of interest because of the tax incentives, including exclusion and deferral of capital gains. IRS released proposed regulations on October 19 that gave practitioners some answers. Bradley T. Borden, a professor of law at Brooklyn Law School, and Alan S. Lederman, a shareholder at the Florida law firm of Gunster, join Bloomberg Tax’s Andrea L. Ben-Yosef in describing these opportunity zones and funds, how practitioners can take comfort in going forward with many of these transactions, what the IRS still needs to address. They also examine how these proposed regulations may influence  a taxpayer’s decision to use qualified opportunity funds as a way to replace real estate that is sold on a tax-deferred basis,  instead of using a Section 1031 like-kind exchange.For more information, see the article in the Bloomberg Tax Real Estate Journal, Rolling Real Estate Gain into a Qualified Opportunity Fund: Comparison with §1031, by Alan S. Lederman and and Bradley T. Borden (Sept. 5, 2018). Link: https://www.bloomberglaw.com/product/tax/document/XDPG43TG000000.

Opportunity zones and opportunity funds were created by the 2017 tax act to encourage business investment in low-income communities. They have attracted a lot of interest because of the tax incentives, including exclusion and deferral of capital gains. IRS released proposed regulations on October 19 that gave practitioners some answers. Bradley T. Borden, a professor of law at Brooklyn Law School, and Alan S. Lederman, a shareholder at the Florida law firm of Gunster, join Bloomberg Tax’s Andrea L. Ben-Yosef in describing these opportunity zones and funds, how practitioners can take comfort in going forward with many of these transactions, what the IRS still needs to address. They also examine how these proposed regulations may influence a taxpayer’s decision to use qualified opportunity funds as a way to replace real estate that is sold on a tax-deferred basis, instead of using a Section 1031 like-kind exchange. For more information, see the article in the Bloomberg Tax Real Estate Journal, Rolling Real Estate Gain into a Qualified Opportunity Fund: Comparison with §1031, by Alan S. Lederman and and Bradley T. Borden (Sept. 5, 2018). Link: <a href="https://www.bloomberglaw.com/product/tax/document/XDPG43TG000000" rel="nofollow" target="_blank">https://www.bloomberglaw.com/product/tax/document/XDPG43TG000000</a>.

What Are the Opportunities in Opportunity Funds?

Artificial Intelligence and Big Data are terms that are in the news. Tax practitioners should be aware that the IRS is using these methods to mine for information, and that could impact whether and how their clients are audited. Carina Federico of Crowell Moring, Michelle Schwerin of Capes Sokol, and Travis Thompson of Sideman &amp; Bancroft join Bloomberg Tax’s Andrea L. Ben-Yosef to talk about where IRS is getting its data, how the use of AI will impact enforcement, and what practitioners should be doing now.Host: Andrea Ben-Yosef

Artificial Intelligence and Big Data are terms that are in the news. Tax practitioners should be aware that the IRS is using these methods to mine for information, and that could impact whether and how their clients are audited. Carina Federico of Crowell Moring, Michelle Schwerin of Capes Sokol, and Travis Thompson of Sideman &amp; Bancroft join Bloomberg Tax’s Andrea L. Ben-Yosef to talk about where IRS is getting its data, how the use of AI will impact enforcement, and what practitioners should be doing now. Host: Andrea Ben-Yosef

How the IRS is Using AI and Big Data

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