Tax Notes Talk

Tax Notes contributing editor Nana Ama Sarfo discusses the SEC’s recently released carbon pricing disclosure rules and their reception from the business community. 

For additional coverage, read Sarfo's article in Tax Notes, "Examining the SEC’s Simpler Carbon Pricing Disclosure Rules."

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 University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

This episode is sponsored by PLI Press. For more information, visit pli.edu/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

William McRae of Cleary Gottlieb discusses the U.S. Tax Court’s decision in YA Global Investments v. Commissioner and what it means for the private equity sector.

For additional coverage, read these articles in Tax Notes:

• Tax Pro Questions Tax Court’s Dealer Analysis in YA Global
• Tax Pros Weigh Impact of YA Global on Fund Industry
• YA Global Footnote Shouldn’t Be Overlooked
• Cayman Islands Hedge Fund Liable for Tax Bill of Over $57 Million

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

Tax Notes Capitol Hill reporters Cady Stanton and Doug Sword discuss the roadblocks the Tax Relief for American Families and Workers Act is facing in the Senate.

For additional coverage, read these articles in Tax Notes:

• Crapo’s Tax Deal Offers Were Non-starters for Dems, Wyden Says
• Finance Republicans Have Problem With Tax Bill’s Retroactivity 
• Wyden Warns It’s Now or Never for R&D and Other Biz Tax Breaks
• Larger Priorities and Slow Discussions Leave Tax Bill in Limbo
• Tax Deal Doesn’t Have Support to Skirt Filibuster, Crapo Says

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.

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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 Stephanie Soong discusses the latest developments surrounding amount B under pillar 1 of the OECD’s two-pillar corporate tax reform plan. 

Listen to our last podcast on amount B: Pillar 1 Amount B: Disagreements and Divides

For additional coverage, read these articles in Tax Notes:

• Amount B Transfer Pricing Approach Doesn’t Deliver, BIAC Says
• Amount B Might Have a Phase 2, Bello Says
• Amount B Won’t Change Australia’s Inbound Distributor Approach
• New Zealand Won’t Adopt Amount B Transfer Pricing Framework
• OECD Sets Out Amount B Transfer Pricing Simplification Framework
• Amount B Tax Certainty Is a Red Line for U.S., Bello Says

Follow us on Twitter:

• Stephanie Soong: @StephanieSoong
• 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

Christine Green of Steptoe & Johnson PLLC discusses the Corporate Transparency Act and the recent litigation regarding its constitutionality.

For additional coverage, read these articles in Tax Notes:

• U.S. Court Declares Corporate Transparency Act Unconstitutional
• Yellen: New Beneficial Ownership Reporting Rules Already Working
• FinCEN Finalizes Access Rule for Beneficial Ownership Reporting
• IRS Criminal Investigators Won’t Enforce New Transparency Rules
• FinCEN Finalizes Reporting Extension Rule Without More Relief

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

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
  
  

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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 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