Tax Notes managing legal reporter Andrew Velarde discusses the economic substance doctrine dispute in Liberty Global Inc. v. United States and its potential implications.

For previous Moore episodes, listen to the following:

• A Recap of SCOTUS Oral Arguments in Moore v. United States
• Moore Money, More Tax Problems? Analyzing Moore v. United States

For additional coverage, read these articles in Tax Notes:

• ABA Section of Taxation Meeting: Liberty Global Is a Warning Against High-Level Business Purpose
• Liberty Global Appeals Economic Substance Loss to Tenth Circuit
• Liberty Global Promises Economic Substance Doctrine Appeal
• Economic Substance Doctrine Constrains Liberty Global

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 TaxBandits. For more information, visit taxbandits.com and use promo code TaxNotes5.

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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

Kelly Phillips Erb, known online as Taxgirl, discusses the 2024 filing season’s challenges and considerations in light of the IRS’s post-IRA funding changes and the potential for congressional action on a tax deal.
 
For additional coverage, read these articles in Tax Notes:

• IRS Hasn’t Been Idle During ERC Moratorium
• IRS Launches Direct-File Platform
• Hopes for Senate Markup of Tax Deal Complicated by Timing
• IRS Unveils Sleeker Notices Ahead of Filing Season
• Tax Deal Puts a Damper on Filing Season Optimism
• Werfel: Shutdown During Filing Season Could Be ‘Very Disruptive’
• Filing Season Tax Changes Could Be Challenging for Direct File

Follow us on Twitter:

• Jonathan Curry: @jtcurry005
• 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 TaxBandits. For more information, visit taxbandits.com and use promo code TaxNotes5.

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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 downward attribution dispute in Altria Group Inc. v. United States and the case’s similarities to Moore.

Listen to our Moore episodes:

• A Recap of SCOTUS Oral Arguments in Moore v. United States
• Moore Money, More Tax Problems? Analyzing Moore v. United States

For additional coverage, read these articles in Tax Notes:

• Analysis: The Excise Power: Altria Waits Its Turn
• Altria’s Case Stayed Pending Realization Decision in Moore
• Altria Challenges IRS Downward Attribution Control Analysis

Follow us on Twitter:

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

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

This episode is sponsored by TaxBandits. For more information, visit taxbandits.com and use promo code TaxNotes5.

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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 global tax transparency efforts, specifically beneficial ownership registries and country-by-country public reporting.

For more, read Sarfo's analysis in Tax Notes: New Year, New Expectations for Global Tax Transparency

Follow us on Twitter:

• Nana Ama Sarfo: @nanaama_sarfo
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

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

This episode is sponsored by 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

Stephanie Do of the Council On State Taxation discusses key state tax policy topics that are likely to see action in 2024, including the expiration of Tax Cuts and Jobs Act provisions.
 
For additional coverage, read these articles in Tax Notes:

• West Virginia Governor Highlights Fiscal 2024 Revenue
• COST Urges California High Court to Block Taxation of Intangibles
• The High Cost of Untaxed Sales
• SALT Cap Workarounds Are Not Always Beneficial, Practitioner Says
• Stakeholders: More Clarifications Needed for New Mexico's Digital Ad Rules
• Voters Reject Wealth Taxes in Texas, Approve Pot Tax in Ohio
• New and Revised Guidance on GILTI, FDII Available in New Jersey

Follow us on Twitter:

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

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

This episode is sponsored by the Tax Attorney Recruiting Event. For more information, visit the-tare.com.

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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 Analysts Chief Operating Officer Jeremy Scott reviews the 2023 developments in U.S. tax legislation and speculates what may lie ahead in 2024.

For more on AI and the Big 4, read this Fortune article.

For additional coverage, read these articles in Tax Notes:

• Businesses Paid More Taxes in Fiscal 2022, COST Report Says
• A Look Ahead: If a Tax Package Materializes, Don’t Blink or You’ll Miss It
• The Biggest Implications of Moore
• IRS Looks to Procure AI Operations Platform
• IRS Cautioned to Be Careful in the Face of Clawbacks
• Republican Taxwriters Push for Expired TCJA Tax Provision Work

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

Tax Notes reporters recap some of the strangest stories they encountered in 2023, from a video game that can prepare tax returns to the IRS attempting to seize a 200-year-old Italian cello.

For additional coverage, read these articles in Tax Notes:

• The ‘Gamification’ of Tax Return Preparation Has Arrived
• Tax Wonk Calls Foul on Massachusetts Surtax After NBA Player Departs
• Taxpayer Hits Sour Note in Quest to Protect Cello From IRS Levy
• Forged Documents Shatter Iranian Seizure Deduction Claim
• Strained Vacation Locales Embrace Tourism Taxes

Listen to other tax oddities episodes:

• Year-End Collection: Tax Oddities of 2022
• Year-End Collection: Tax Oddities of 2021
• Year-End Collection: Tax Oddities of 2020

Follow us on Twitter:

• Caitlin Mullaney: @MullaneyWrites
• Emily Hollingsworth: @EmilyHoll9
• Sarah Paez: @PaezWrites
• 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 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