Tax Notes Talk

Jonathan Curry and Andrew Velarde discuss the draft regulations Tax Notes obtained from the Office of Information and Regulatory Affairs.

For additional coverage, read these articles in Tax Notes:

• New OIRA Drafts Reveal Tweaks to TCJA Guidance
• OIRA Leadership Shuffle Opens Door to Tax Reg Review Shake-Up
• OIRA’s Tax Reg Reviews Remain a ‘Black Box’ Despite Draft Regs
• Spotlight on OIRA’s Review Process Eases Politicization Concerns
• OIRA’s Imprint on Tax Regs Revealed in New Cache of Documents

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

Jared Dunkin, head of tax at a Washington, D.C.-based publicly traded multinational, discusses the role practitioners have in mentoring and developing tax professionals. Dunkin is author of the book, Brass Tax: 14 Actionable Insights to Power Your Success.

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

Steve Dixon and Kevin Kenworthy of Miller & Chevalier discuss the U.S. Supreme Court's recent decision to uphold Auer deference in Kisor v. Wilkie and what it means for the Treasury and the IRS.

For additional coverage, read these articles in Tax Notes:

• Auer Deference Survives, But ‘Neutered’ and ‘Zombified’
• U.S. Supreme Court Decision on Auer Won’t Affect Tax Cases
• Conservative Justices Question Feasibility of Auer’s Survival
• Gorsuch Dissent Could Signal Beginning of the End for Chevron
  
  
  
  
  

Kristen Parillo and Ryan Finley discuss the Ninth Circuit's new opinion in Altera v. Commissioner upholding a regulation requiring that parties to a cost-sharing arrangement share stock-based compensation.

For additional coverage, read these articles in Tax Notes:

• Altera, the Sequel — Jurisprudence Catches Up With BEPS
• Altera Decision Revives Commensurate With Income Standard
• Ninth Circuit Again Upholds Cost-Sharing Regs in Altera
  
  
  
  
  

Tax Notes Today State reporter Paige Jones discusses the developments in states since the U.S. Supreme Court's June 21, 2018, decision in South Dakota v. Wayfair Inc.

See the Tax Notes Nexus Tracker and these articles for more coverage:

• One Year Later: Experts Discuss Aftermath, Future Impact of Wayfair
• No New Streamlined Member States a Year After Wayfair
• NCSL SALT Task Force Contemplates Its Future Post-Wayfair
• Remote Sellers Seeking Relief as States Shift to Marketplace Laws
• New Hampshire Wages War Against Wayfair
  
  
  
  
  
  
  
  
  

Stephanie Johnston discusses the G-20 finance ministers' reaction to the OECD's workplan to achieve consensus on taxing the digital economy. The G-20 finance ministers met recently in Fukuoka, Japan.

For more coverage, read these articles in Tax Notes:

• G-20 Finance Ministers Endorse OECD Roadmap for Digital Economy
• France Aims for G-7 Consensus to Set Stage for Digital Tax Deal
• OECD Sets Course Toward Global Digital Tax Deal by 2020
• Countries Greenlight OECD Digital Tax Workplan
  
  
  
  
  
  
  
  
  

Eric Yauch and Andrew Velarde highlight the major themes that came up at the American Bar Association Section of Taxation meeting in Washington, including interesting insights into recent and coming regulations.

For more coverage of the ABA meeting, read these articles in Tax Notes:

• IRS Considering More Safe Harbors in O-Zone Rules
• Partnerships Can Defer Section 1231 Gain Under O-Zone Rules
• Treasury Carefully Considering Interest Definition in Final Rules
• Triple Net Lease Changes Likely in Final 199A Safe Harbor
• IRS Won’t Be as Forgiving of TCJA Comment Deadlines
• Wilkins Predicts Temporary Regs Will Disappear From Rulemaking
• Treasury, IRS Open to Suggestions on PTI Simplification
• U.S. Officials Urging Delay of DSTs as Negotiations Continue
• Looming Tax Court Trial Will Test Economic Substance Doctrine
• Bridging the Guidance Enforcement Gap Is IRS Priority
  
  
  
  
  
  
  
  
  
  
  
  
  

Andrew Velarde talks to Joe Calianno of BDO about the pending final guidance on the global intangible low-taxed income provision enacted as part of the Tax Cuts and Jobs Act, and Paige Jones talks to Scott Smith of BDO about the state responses to GILTI.

At a breakfast panel of the American Bar Association Tax Section meeting in Washington, David Stewart talks to Lilian Faulhaber and Will Morris about the taxation of the digital economy. Lilian Faulhaber is a professor at Georgetown Law, and Will Morris is the deputy global tax policy leader at PwC.