In the third of a three-episode series, former senior Treasury official Chip Harter discusses his experience creating the international tax guidance for the Tax Cuts and Jobs Act and the evolution of those provisions. 

Listen to the other two episodes in the series:

•  The TCJA Five Years Later: State Tax Issues
• The TCJA Five Years Later: Federal Tax Issues

For additional coverage, read these articles in Tax Notes:

• Proposed Regs Target Consolidated Group CFC Income Inclusions
• Anti-Injunction Act Bars Silver’s GILTI Suit, Court Finds
• Government Pursues Liberty Global for $284 Million in DRD Dispute
• Spectrum Brands Files Protective Return After Liberty Global
• Biden Wants to Drop the BEAT and Replace It With Pillar 2

Follow us on Twitter:

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

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This episode is sponsored by the District of Columbia Bar Taxation Community. For more information, visit https://site.pheedloop.com/event/TaxConference2023/home/?utm_source=TaxNotes&utm_medium=Banner&utm_campaign=TaxConference&utm_id=TaxConference.

This episode is sponsored by SafeSend. For more information, visit safesend.com.

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Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart

In the second of a three-episode series, Jennifer Acuña, now with KPMG and former tax counsel for the Ways and Means Committee, discusses how guidance for the Tax Cuts and Jobs Act is still evolving.

Listen to the first episode in the series here: The TCJA Five Years Later: State Tax Issues

For additional coverage, read these articles in Tax Notes:

• This Isn’t Your Father’s Tax Extender Package
• Year-End Tax Title Still in Rumor Realm
• Dems Ready to Deal; GOP Is a ‘Maybe,’ Former Top Pelosi Aide Says
• Lame-Duck Talks May Be Stalled Through December 6
• Lack of GOP Wave Dims Section 199A Permanence Chances, Group Says
• Research Amortization Procedural Guidance Expected This Year

In our “Editors’ Corner” segment, Michelle Markham, a professor at Bond University, chats about her Tax Notes column, Markham on Managing Disputes, and her latest installment, “Advancing Tax Certainty: The New OECD Bilateral APA Manual.” 

Follow us on Twitter:

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

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This episode is sponsored by SafeSend. For more information, visit safesend.com.

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart

In the first of a three-episode series, Steven Wlodychak, formerly with EY, discusses the creation of the SALT cap deduction by the Tax Cuts and Jobs Act and how states addressed it and other changes.

 For additional coverage, read these articles in Tax Notes:

• Consistent Guidance on SALT Cap Workarounds Needed, Panel Says
• California Governor Signs SALT Cap Workaround Fix
• Pennsylvania Bill Would Create SALT Cap Workaround
• ‘No SALT, No Deal’ Becomes No More

Follow us on Twitter:

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

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This episode is sponsored by SafeSend. For more information, visit safesend.com.

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 and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart

Tax Notes chief correspondent Stephanie Soong discusses how countries are approaching implementation of the OECD’s two-pillar corporate tax reform plan and the future of the OECD after Pascal Saint-Amans’s departure. 

 Listen to more podcast episodes on the OECD's tax reform plan:

• Implementation Issues: An OECD Tax Reform Project Update
• The End Is Nigh: An Update on the OECD Tax Reform Plan
• The Beginning of the End? An Update on the OECD Tax Reform Plan

 For additional coverage, read these articles in Tax Notes:

• ECOFIN To Soon Try Again for Global Minimum Tax Agreement
• Indian Barrister Calls for Global Indirect Tax Treaty
• OECD Seeks to Improve CbC Reporting Standard
• U.K. Treasury Confirms Plan to Implement Pillar 2
• G-20 Heads Urge Countries to Finish Work on Pillar 1 Tax Rules
• Global Tax Deal Could Change Views on CCTB, EU Official Says

In our “Editors’ Corner” segment, Naomita Yadav, a partner at Withers in San Francisco, chats about her Tax Notes column, (Tax) Matters of Life and Death, and her latest installment, “To PTE or Not to PTE: Estate Planning and SALT PTE Elections.” 

Follow us on Twitter:

• Stephanie Soong: @StephanieSoong
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

**
This episode is sponsored by SafeSend. For more information, visit safesend.com.

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

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart

Stephanie Hunter McMahon of the University of Cincinnati College of Law discusses why labor performed by incarcerated workers should be subject to tax.
 
For more, read Hunter McMahon's article in Tax Notes, "Prison Work Is Taxing and Should Be Taxed."

Follow us on Twitter:

• Joe Thorndike: @jthorndike
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

**
This episode is sponsored by 360 Coverage Pros. For more information, visit 360coveragepros.com/taxnotes.

This episode is sponsored by SafeSend. For more information, visit safesend.com.

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

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart

In the second of a two-episode series, Orly Mazur of SMU Dedman School of Law discusses her views on the tax implications of increasing automation and the alternatives to a robot tax.

Listen to the first episode in this series, "Should We Have a Robot Tax? Part 2."

For more on Orly, read "A Conversation With Orly Mazur: Taking on Tax and Tech."

Follow us on Twitter:

• Marie Sapirie: @mariesapirie
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

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

This episode is sponsored by SafeSend. For more information, visit safesend.com.

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

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart

In the first of a two-episode series, Ryan Abbott of the University of Surrey discusses his views on the tax implications of increasing automation and the need for a robot tax.

For more, read Abbott and Bogenschneider's article, "Should Robots Pay Taxes? Tax Policy in the Age of Automation."

In our “Editors’ Corner” segment, Elizabeth Stevens, a member in the international tax practice at Caplin & Drysdale Chtd. in Washington, chats about her coauthored Tax Notes piece, “Transfer Pricing's Next Generation.”

Follow us on Twitter:

• Marie Sapirie: @mariesapirie
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

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

This episode is sponsored by SafeSend. For more information, visit safesend.com.

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

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart

Former IRS Commissioner Mark Everson, now with Alliantgroup, discusses the need to identify the agency’s next leader and how the IRS should use its additional funding from the Inflation Reduction Act.

For additional coverage, read these articles in Tax Notes:

• TIGTA Tees Up Hot-Button Issues for Review in 2023
• Leaderless IRS Threatens Credibility Crisis in Key Months Ahead
• Republicans Voice Concerns to GAO on IRS Funding Oversight
• Former Officials: Success of IRS Funding Boost Is at ‘Serious Risk’
• Ex-IRS Official Predicts Rapid Benefits From IT Upgrades
• Senate GOP Frets Over ‘Largely Unbridled’ IRS Funding

Follow us on Twitter:

• Jonathan Curry: @jtcurry005
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

**
This episode is sponsored by 360 Coverage Pros. For more information, visit 360coveragepros.com/taxnotes.

This episode is sponsored by SafeSend. For more information, visit safesend.com.

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

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart

U.S. Tax Court Chief Judge Kathleen Kerrigan discusses the court’s post-COVID transition and case management system, and how the additional funding from the Inflation Reduction Act may be used.

Listen to our episode with Judge Foley, "Talking With the Tax Court Chief Judge: A Year of Change."

For additional coverage, read these articles in Tax Notes:

• Company Looks to Reverse Tax Court Software Fee Deduction Ruling
• Medtronic II’s Unspecified Method Raises Specific Questions
• Tax Court Should Never Have Heard Whistleblower Case, IRS Says
• Tax Court’s Sealed Case Iceberg Will Soon Be Fully Thawed

In our “Editors’ Corner” segment, Filippo Noseda, a partner at Mishcon de Reya LLP and a visiting professor at King’s College in London, chats about his Tax Notes series on potentially corrupt behavior with FATCA and EU public registers.   

Follow us on Twitter:

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

**
This episode is sponsored by 360 Coverage Pros. For more information, visit 360coveragepros.com/taxnotes.

This episode is sponsored by SafeSend. For more information, visit safesend.com.

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

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart

It’s Tax Notes Talk’s fifth anniversary! Host David Stewart discusses the history of the podcast with current and former members of the team: Gulnar Zaman, Derek Squires, Paige Jones, and Jordan Parrish.

We want to hear from you, our listeners! To fill out a short, two-minute survey, visit taxnotes.co/podcastsurvey.

Follow us on Twitter:

• Gulnar Zaman: @zgulnar
• Paige Jones: @paigeleejones
• Jordan Parrish: @JoParrish96
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

**
This episode is sponsored by 360 Coverage Pros. For more information, visit 360coveragepros.com/taxnotes.

This episode is sponsored by SafeSend. For more information, visit safesend.com.

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

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart