Tax Notes Talk

Tax Notes contributing editor Robert Goulder shares his take on the effects of the Foreign Account Tax Compliance Act and common reporting standards on the feasibility of taxing foreign assets.

Listen to our previous episodes on taxing hidden assets:

• The Constitutionality of Penalties on Undeclared Assets
• America the Tax Haven? Exploring the U.S. Trade Deficit

For more coverage, read the following in Tax Notes:

• Trump Vows to End ‘Double Taxation’ of Overseas Citizens
• Court Tells DOJ No Do-Over in Venture Capitalist FBAR Case
• EU, Belgium Say Domestic Bank Secrecy Hinders Tax Transparency
• U.S., Switzerland to Exchange Info Under New FATCA Deal From 2027
• IRS Approves Argentina’s Data Security for FATCA Exchanges
• Transparency Not a Threat to Privacy, Tax Justice Network Says

For information about our live Taxing Issues event, visit: https://events.taxanalysts.org/tawebinar112024 

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• Bob Goulder: @RobertGoulder
• 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

Monisha Santamaria and Nick Tricarichi of KPMG discuss the scope of the latest guidance on the corporate alternative minimum tax and its impact on tax and accounting professionals.

Listen to our previous episode on CAMT: Navigating New Guidance on the Corporate Alternative Minimum Tax

For more coverage, read the following in Tax Notes:

• Exempt Orgs Get Temporary Break From Filing Corporate AMT Form
• Corrections Coming for Corporate AMT Proposed Regs
• Treasury Downplays FTC Timing Concerns in Corporate AMT Regs
• More Corporate AMT Safe Harbors Are on the Table
• Analysis: CAMTyland Adventures, Part V: Coping With CAMTyland Grief

For information about our live Taxing Issues event, visit: https://events.taxanalysts.org/tawebinar112024 

Follow us on X:

• Chandra Wallace: @ChandraSWallace
• 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 White House reporter Alexander Rifaat discusses the tax policies proposed by Vice President Kamala Harris and former President Trump.

For more coverage, read the following in Tax Notes:

• Trump Proposes Tax Write-Off for Generator Purchases
• Trump Proffers Tax Incentives for Car Owners, Manufacturers
• Trump’s Plan Would Swell Deficit More Than Harris’s, Study Says
• No Indication Vance Will Release Tax Returns
• Harris Proposes New Manufacturing Tax Credit
• Unrealized Capital Gains Proposal Faces Uncertain Path
• Harris Says ‘Trump Tax’ Would Cost Americans $4,000 Annually
• Harris Held Talks With Union Before Making Tip Pledge

Audio clips obtained from C-SPAN.

Follow us on X:

• Alexander Rifaat: @AlexRifaat
• 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 contributing editor Robert Goulder discusses the history of foreign bank account reporting penalties and how two recent court cases could affect the FBAR regime. 

For more coverage, read the following in Tax Notes:

• Jury Finds Professor’s FBAR Failures Willful
• FBAR Penalty Circuit Split Has Potential for Supreme Court Review
• Schwarzbaum FBAR Penalty Dispute Results in Circuit Split
• Court Tells DOJ No Do-Over in Venture Capitalist FBAR Case
• Ninth Circuit Approves Prejudgment Interest for FBAR Penalties

Follow us on X:

• Bob Goulder: @RobertGoulder
• 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

Professors Kenneth Austin and Hillel Nadler discuss the policies that they believe make the United States a tax haven, and the resulting effects on the economy.

For more, read Nadler and Austin's article in Tax Notes, "America the Tax Haven and Its Trade Deficits."

Listen to more Tax Notes Talk episodes about tax havens:

• Bad Credit: A Look at Switzerland’s Bank Secrecy
• Let’s Talk Tax Havens: The EU Blacklist and the Pandora Papers

For more coverage, read the following in Tax Notes:

• EU to Remove Antigua and Barbuda From Tax Blacklist
• Researchers Try to Quantify Firms’ Use of Tax Havens After TCJA
• BEPS Activity May Have Declined in Tax Havens, OECD Reports
• Montana DOR Amends Code to Remove Tax Haven Language
• The EU Tax Blacklist: A Six-Year Journey Toward Compliance

Follow us on X:

• 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 contributing editor Nana Ama Sarfo discusses methane-related tax policy and how it might lead to future taxation of greenhouse gas emissions.

For more on taxing greenhouse gases, listen to Is Carbon Pricing the Best Way to Mitigate Climate Change?

For additional coverage, read Sarfo's analysis in Tax Notes: The Future of Carbon Taxes Could Lie in Methane

Follow us on X:

• Nana Ama Sarfo: @nanaama_sarfo
• 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 contributing editor Ryan Finley breaks down the EU Court of Justice’s recent ruling that Ireland granted €13 billion of unlawful state aid to Apple and its implications for state aid analysis. 

For more coverage, read the following in Tax Notes:

• Irish Finance Minister Defends Tax System After Apple Decision
• CJEU Reinstates €13 Billion State Aid Decision Against Apple
  
  

Follow us on X:

• Ryan Finley: @ryanmfinley
• 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

Alan McLean, chair of the tax committee at Business at OECD, discusses the developments in the international business tax world during his tenure and the committee’s priorities.

Listen to our episode with Will Morris, former chair of the tax committee, here: The Tax Diplomat: Reflections From Former BIAC Tax Chair

For more coverage, read the following in Tax Notes:

• OECD Targets Country Benefits That May Weaken Pillar 2 Rules
• Businesses Call for Central Platform for Global Minimum Tax Data
• GLOBE Permanent Safe Harbor Idea May Boost EU Competitiveness

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

Do you have questions about tax policy in the 2024 election? Submit your questions here.

Steve Rosenthal of the Urban-Brookings Tax Policy Center and Don Susswein of RSM discuss how Congress should handle agency delegation following the Loper Bright decision. 

For more from Rosenthal and Susswein, read the following:

• Congress Can Maintain IRS Rulemaking Authority
• What About Vague ‘Delegated’ Tax Regulations?

For additional coverage, read the following articles in Tax Notes:

• DOJ, FedEx Contest Loper Bright’s Effect in Offset Earnings Case
• Loper Bright Casts Doubt on SECA Guidance Plan, Tax Pros Say

Follow us on X:

• 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

Do you have questions about tax policy in the 2024 election? Submit your questions here.

Tax Notes Capitol Hill reporters Cady Stanton and Doug Sword assess the tax policy items on Congress’s slate this fall, from IRS funding to TCJA extenders, and the potential implications of the upcoming elections.

For additional coverage, read these articles in Tax Notes:

• Tax Extenders Menu Heavy With Energy, Business Tax Breaks
• Tax Package Could Be Useful Lame-Duck Launching Point
• Lengthy Tax Extender Wish List Awaits Lame-Duck Session
• House GOP Taxwriters Warn of Impacts From Letting TCJA Expire
• Trump Makes Murky Claim of Quadrupled Taxes if TCJA Expires

Follow us on X:

• Cady Stanton: @cady_stanton
• Doug Sword: @doug_sword
• 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