Tax Notes Talk

Tax Notes contributing editor Ryan Finley discusses the latest updates in recent transfer pricing cases Eaton and Medtronic II. 

Listen to related episodes:

• Transfer Pricing Litigation Update
• Coca-Cola Transfer Pricing Challenge Fizzles

For additional coverage, read these articles in Tax Notes:

• Analysis: Medtronic and the Role of Unspecified Transfer Pricing Methods
• Medtronic Might Trigger Up to $2 Billion Tax Liability
• Sixth Circuit Sides With Eaton in APA Cancellation Appeal
• Medtronic II’s Unspecified Method Raises Specific Questions

In our “Editors’ Corner” segment, Fernanda Kotzias, a counselor at the Brazilian Administrative Tax and Customs Court of Appeal, chats about her coauthored Tax Notes piece, “Brazil-U.S. Trade Agreement: A New Chapter for Trade Facilitation.”

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

Follow us on Twitter:

• 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 and Audio Engineer: Jordan Parrish
Guest Relations: Alexis Hart

Lauren Collins of Vinson & Elkins LLP provides an overview of the new tax credits designed to reduce greenhouse gas emissions in the Inflation Reduction Act. 

Listen to our other episodes on the tax-related provisions in the Inflation Reduction Act:

• $80 Billion in New Funding: What’s Next for the IRS?
• Analyzing the Corporate Alternative Minimum Tax

For additional coverage, read these articles in Tax Notes:

• U.S. Is Lagging on Social Cost of Carbon, Study Says
• Lawmakers Seek Assistance for Clean Energy and EV Tax Credits
• Yellen to Promote New Tax Measures With Speaking Tour

Follow us on Twitter:

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

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This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.

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

Robert Kerr of Kerr Consulting LLC discusses how the $80 billion of additional funding for the IRS in the Inflation Reduction Act could be best used by the agency. 

For additional coverage, read these articles in Tax Notes:

• Backlog Thwarted IRS’s ‘Well-Planned’ IT Modernization Strategy
• IRS Urged to Budget for Transparency
• Yellen to Promote New Tax Measures With Speaking Tour
• Tax Professionals See Little to Fear in IRS Hiring Blitz
• CBO: IRS Funding Won’t Generate Much From Taxpayers Under $400K

In our “Editors’ Corner” segment, Sarah-Jane Morin, a partner with Morgan, Lewis & Bockius LLP, chats about her coauthored Tax Notes piece, “How the Definition of Digital Asset Brokers Was Brokered.”

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

Follow us on Twitter:

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

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This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.

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

Caroline Rule of Kostelanetz & Fink LLP discusses the post-Roe tax complications for employers covering abortion-related interstate travel expenses.

For more, read Rule's article, "Tax Implications of Dobbs for Interstate Travel Expenses to Obtain Abortions," in Tax Notes.

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

Follow us on Twitter:

• Caitlin Mullaney: @MullaneyWrites
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes
  
  

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This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.

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

Professor Jeremy Bearer-Friend of the George Washington University Law School highlights key areas of the IRS’s tax enforcement where racial bias can occur.
 
For more, read Bearer-Friend's article, "Colorblind Tax Enforcement."

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

Listen to more Tax Notes Talk episodes from our critical tax theory series:

• State Tax Authority and Native Americans: Complex and Convoluted
• Wealth, Inequality, and Taxes in the U.S.
• Feminism and the Tax Code
• Taxes and the LGBTQ Community
• Addressing Racial Inequity in State and Local Tax Policy
• The Tax Code and Economic Justice in America
• How Racial Diversity Shaped U.S. International Tax Policy

Follow us on Twitter:

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

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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

Reuven Avi-Yonah of the University of Michigan Law School discusses the new corporate alternative minimum tax and how it intersects with international taxation.

For additional coverage, read these articles in Tax Notes:

• Inflation Reduction Act Raises Pillar 2 Hopes and Concerns
• Hard Part Begins for IRS and Treasury as Biden Signs Reconciliation Bill
• Critics Recall BURP in Debate Over Corporate Minimum Tax

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

Follow us on Twitter:

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

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This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.

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

Kyle Pomerleau of the American Enterprise Institute discusses the key tax provisions of the Inflation Reduction Act and what they mean for the future of tax policy.

For additional coverage, read these articles in Tax Notes:

• House Democrats Tee Up Tax Bill Debate and Nix GOP Amendments
• Critics Recall BURP in Debate Over Corporate Minimum Tax 
• Democrats Play Whack-a-Mole as GOP Rages Against IRS Funding 
• Partnership Rules Likely at Root of Corporate Minimum Tax Fight
• Biden and Democrats Relish Passage of Reconciliation Bill

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

Follow us on Twitter:

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

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This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.

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

For more information and to download the Tax Advisory Industry Report, visit taxnotes.co/report.

For more information about the Tax Analysts Public Service Fellowship, visit our press release at taxnotes.com/fellowship.

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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

Tax Notes reporter Benjamin Guggenheim discusses the latest tax legislation on Capitol Hill: the recently passed CHIPS and Science Act and the revived reconciliation bill known as the Inflation Reduction Act.

For additional coverage, read these articles in Tax Notes:

• Sinema Wants Carried Interest Out of Reconciliation, Reports Say
• Clawbacks Will Prevent Companies From Exporting CHIPS Benefits
• Ex-Treasury Secretaries Support Inflation Reduction Act
• Democrats Hit Back at Criticism of Inflation Reduction Act
• Reconciliation Tax Reform Limited by Delicate Negotiations
• Computer Chip Bill Passes House, Heads for Biden Signature
• Key Senators Reach Deal on Corporate Tax, Carried Interest

In our “Editors’ Corner” segment, John Craig, an associate in the Washington office of Gibson, Dunn & Crutcher LLP, chats about his coauthored Tax Notes piece, “The Appeals Access Saga Continues.”

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

Follow us on Twitter:

• Benjamin Guggenheim: @ben_guggenheim
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

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This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.

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

For more information about the Tax Analysts Public Service Fellowship, visit our press release at taxnotes.com/fellowship.

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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

Martin A. Sullivan, Tax Analysts’ chief economist, revisits the United States’ economic path to inflation and discusses mitigation efforts for a possible recession.
 
For more inflation coverage on the podcast, listen to Inflation, Tax, and the COVID-19 Economy.

For additional coverage, read these articles in Tax Notes:

• Grassley Follows Up With Second Inflation-Indexing Package
• North Carolina Republicans' Budget Preserves Income Tax Cuts
• California Budget Deal Includes Billions in Inflation Relief

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

Follow us on Twitter:

• Martin Sullivan: @M_SullivanTax
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

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

For more information and to download the Tax Advisory Industry Report, visit taxnotes.co/report.

***
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 Johnston recaps the agreement on the OECD’s two-pillar corporate tax reform plan and discusses recent roadblocks to full implementation.

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

• 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
• New Year, New Tax Rules? An OECD Tax Reform Project Update

For additional coverage, read these articles in Tax Notes:

• U.K. Moves to Implement OECD-Brokered Global Minimum Tax Rules
• G-20 Ministers Push Ahead on Global Tax Reform Amid U.S. Hurdles
• White House Downplays Global Tax Deal Concerns
• India Calls for Syncing Pillar 2 Treaty Rule and Amount B Rules
• OECD Fills in More Blanks on Amount A Draft Model Tax Rules
• Treasury to Nix Tax Treaty With Hungary for EU Minimum Tax Veto
• Support Rises for Circumventing Hungary on Pillar 2
• Hungarian Lawmakers Nix EU Pillar 2 Minimum Tax Directive

In our “In the Pages” segment, Heydon Wardell-Burrus, a researcher at the Oxford Centre for Business Taxation, chats about his Tax Notes piece, “Can Pillar 2 Be Leveraged to Save Pillar 1?”

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

Follow us on Twitter:

• Stephanie Soong Johnston: @SoongJohnston
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

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This episode is sponsored by Avalara. For more information, visit avalara.com/taxnotes.

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

For more information about the Tax Analysts Public Service Fellowship, visit our press release at taxnotes.com/fellowship.

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