Tax Notes Talk

Emily Foster and Eric Yauch discuss some of the key elements of the recently proposed regulations on the business interest deduction limitation.

For more extensive coverage, read these articles in Tax Notes:

• Interest Rule Leaves Securities Traders in a Jam
• Interest Regs Muddy Partnership Debt-Equity Decisions
• Interest Deduction Regs’ Antiavoidance Rule Causes Reassessments
• Interest Allocation Rules Could Wreak Havoc on Groups
• Interest Regs Require Taxpayers to Decide on ‘Early Adoption’
• Interest Regs Raise Same Real Estate Issues as 199A Rules
• Interest Deduction Regs Cover More Than Just Interest
• Interest Regs Tackle Some Passthrough Issues, Leave Others Open
  
  
  
  
  
  
  
  
  
  
  
  
  

David Stewart talks to Porus Kaka at the International Taxation Conference in Mumbai about various tax issues, including India's new permanent establishment concept, taxation of the digital economy, and the effects of the Tax Cuts and Jobs Act.

For related coverage, read these articles in Tax Notes:

• India’s Tax Chief: Digital Taxation Needs Fair Allocation Rules
• India’s New PE Scheme Limited by Unanswered Questions
• India Seeks Input on Digital PE for Taxing Foreign Companies
• India's Equalization Levy Brings In Nearly $90 Million
• India's 2018 Budget Introduces Digital PE Rules
  
  
  
  
  
  
  
  
  
  
  

Jad Chamseddine and Paul Jones discuss the Wayfair decision and the long-term implications for state and foreign taxes.

Listen to previous episodes on Wayfair:

• Navigating the Post-Wayfair World
• U.S. Supreme Court Overturns Quill

For additional coverage, read these articles in Tax Notes: 

• Texas Bill Would Provide Statewide Local Tax Rate for Remote Sellers
• Wayfair Settlement Is a Missed Opportunity
• South Dakota and Wayfair Litigants Reach Settlement
• California Looks to Follow South Dakota on Remote Sales Tax Enforcement
• Alabama Remote Sales Tax Law Could Be Model for Other States
• California Likely to Implement Wayfair in 2019
• Beyond Wayfair: Implications for State and Foreign Taxes
  
  
  
  
  
  
  
  
  
  

Lauren Loricchio provides an update on Amazon's choice of two HQ2 locations: Northern Virginia and the borough of Queens in New York City.

For more coverage in Tax Notes, read:

• Louisville Won't Release HQ2 Bid, Despite Amazon Announcement 
• Amazon's New York City HQ2 Site Eligible for Federal Tax Breaks
• Georgia First Also-Ran to Reveal Incentives Offered to Amazon
• Amazon to Split HQ2 Between New York City, Northern Virginia
• Group Slams Reports of Two Amazon HQ2s as 'Bait and Switch'
• Bezos Will Let His Heart Lead Him to Amazon's New Home
• Pittsburgh to Appeal Order Requiring Release of Amazon HQ2 Proposal
  
  
  
  
  
  
  
  
  

A roundup of the November 6 midterm election results. Asha Glover and Stephen Cooper discuss what changes to look for in the new Congress, including the makeup of the House Ways and Means Committee and the tax agendas. Paul Jones and Lauren Loricchio discuss the results in the state gubernatorial races as well as the tax ballot measures approved by state voters.

For more coverage in Tax Notes, see:

• Senators Agree on IRS Reform, Extenders as Lame-Duck Priorities
• Brady Eyes Dozens of TCJA Technical Fixes in Lame Duck
• Ways and Means to Review Tax Extenders This Week
• Tax Committees Brace for Turnover in Next Congress
• Trump Open to Corporate Rate Increase to Get Middle-Income Tax Cut
• Neal Wants Trump to Voluntarily Give Up Returns
• Gubernatorial Winners Set to Advance Tax Proposals
• Voters OK State Tax Ballot Measures on Marijuana, Income Tax Cap
• Midterms Stifle GOP Tax Plans as Democrats Take Control in House
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  
  

Jonathan Curry discusses the IRS's rules addressing strategies using trusts to sidestep the section 199A deduction limitations and claim multiple deductions.

For more coverage in Tax Notes, see: 

• 199A Regs’ Multiple Trust Rule May Invite Challenges
• Creating Just One Trust for the 199A Deduction? Think Again
• Non-Grantor Trusts Still Useful in TCJA Planning
• IRS Drops Hammer on 199A, SALT Cap Workarounds
• IRS Likely to Trounce 199A Trust Planning Strategy
  
  
  
  
  

Eric Yauch discusses a provision of the Tax Cuts and Jobs Act that hasn't received a lot of attention: section 461(l), which caps excess business losses at $250,000 for individuals and $500,000 for joint filers.

For more coverage in Tax Notes, see:

• New Loss Limitation Is on Government’s Radar
• New Loss Limitation Hard to Calculate, Interpret With Other Rules
  
  
  
  
  

Jeremy Cape of Squire Patton Boggs discusses the tax issues arising from Brexit.

For related coverage on Brexit, read these articles in Tax Notes:

• U.K. Tax is Lesser Concern in No-Deal Brexit
• U.K. Backs Customs Agents Facing Brexit Capacity Challenge
• EU, U.K. Leaders Willing to Extend Brexit Transition Period
• Brexit Talks at Impasse Over Customs Backstop Proposal 
• EU Proposes 'Least Intrusive' Customs, VAT Checks After Brexit
• The U.K. Can’t Afford to Become a Tax Haven, Says Labour Politician
• EU Steps Up Complaint Against U.K. Over €3 Billion Customs Fraud
• HMRC Warns of Customs and VAT Impact of No-Deal Brexit

 For more on the Jaffa Cakes and Pringles debate, see:

• Cake or Biscuit? Why Jaffa Cakes Excite Philosophers
• The Lord Justice Hath Ruled: Pringles Are Potato Chips
  
  

Andrew Breiner talks to practitioners about the various issues raised by state efforts to tax peer-to-peer car rentals.

For related coverage, read these articles in Tax Notes:

• Illinois Governor Vetoes Car Sharing Bill, Proposes Own Plan
• States Look to Tax the Car-Sharing Industry
• Airbnb and the Sharing Economy
  
  
  
  
  
  

Andrew Velarde highlights the significant insights from the recent American Bar Association Section of Taxation meeting in Atlanta, where the Tax Cuts and Jobs Act was once again the main topic of discussion.

For additional coverage of the ABA meeting, read these articles from Tax Notes:

• TCJA Shaping Global Discussion as Several Regs Near Completion
• U.S. Antiabuse Rules, Imperfect International Tax Regs Coming
• Transition Tax Guidance Will Extend Transfer Agreement Due Date
• 'Guideposts’ Revealed for R&D-intensive Business Spinoffs
• Treasury Clarifies 199A De Minimis Rules Have Cliff 
• Rental Property Ownership Could Decide 199A Effects
• Treasury: Qualified Improvement Property Needs Technical Correction
• Bonus Depreciation Regs Unlikely to Be Finalized This Year