Tax Notes contributing editor Ryan Finley discusses the latest developments in three transfer pricing cases — Medtronic, 3M, and Abbott Labs — and their implications for the future.

For additional coverage, read these articles in Tax Notes:

• Business Groups Urge Eighth Circuit to Overturn Tax Court in 3M
• Medtronic Budges on CUT Method in Round 2 at Eighth Circuit
• Abbott Labs Revives Fight Over Stock Options in Transfer Pricing
• Blocked Brazilian Income Can’t Be Taxed in U.S., 3M Brief Argues
• 3M Challenges Blocked Income Regs at Eighth Circuit
• Government Resumes Defense of Its Transfer Pricing for Medtronic
• Coca-Cola’s Brazilian Income Not Blocked, U.S. Tax Court Says

In our “Editors’ Corner” segment, Edith Brashares, former director in the Treasury Office of Tax Analysis, chats about her coauthored Tax Notes piece, “Is the Economic Analysis Section of Regs Worth the Trouble?” 

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.

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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 Edward Fox and Zachary Liscow discuss their proposal for a new tax on billionaires that would apply to borrowing against their assets.

For more, read Fox and Liscow's article, "No More Tax-Free Lunch for Billionaires: Closing the Borrowing Loophole," in Tax Notes.

For more on wealth taxes, listen to The Wealth Tax Debate.

Follow us on Twitter:

• Robert Goulder: @RobertGoulder
• 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.

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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 Capitol Hill reporters Cady Stanton and Doug Sword discuss the key provisions of the Tax Relief for American Families and Workers Act and its potential paths for passage in the Senate.

For additional coverage, read these articles in Tax Notes:

• House Kills SALT Marriage Penalty Bill in Procedural Vote
• Smith Combats Claims Senate Republicans Weren’t in Tax Talks
• Senate Border Traffic Jam Pushes Tax Bill Back Weeks, at Least
• House Tax Deal Vote Hasn’t Swayed Senators Seeking Markup

Follow us on Twitter:

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

For more information on Ask Blue J, visit bluej.com/ask.

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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

Professor Roberta Mann of the University of Oregon School of Law explains how taxing single-use plastics could help combat their environmental effects. 

For more, read Mann's article, "Targeting Plastic Pollution with Taxes."

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 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 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
  
  

**
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
  
  

**
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.

***
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.

***
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.

***
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

***
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