Tax Analysts Chief Operating Officer Jeremy Scott reviews the 2024 developments in U.S. tax legislation and speculates what may lie ahead in 2025.

For additional coverage, read these articles in Tax Notes:

• Direct File Expected to Face Scrutiny by Incoming Administration
• Tax Bill Uncertainty May Dampen Business Activity
• What to Expect From Scoring the 2025 Tax Bill
• The Coming Tax Package: To Count Tariffs or Not
• IRS Hiring Poised to Be Tested by Trump’s Remote Work Disapproval
• Trump Policy Priorities Could Push Tax Into the Back Seat

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• 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

Tax Notes reporters recap some of the most memorable stories they encountered in 2024, from “pig butchering” scams to a denied late-filing excuse citing Christmas stress.

For additional coverage, read these articles in Tax Notes:

• Maine Enacts Tax Credit to Keep Portland Baseball Team
• DraftKings Kills Betting Tax Surcharge Proposal
• DraftKings Announces Surcharge Plan on States With High Betting Taxes
• 'Pig Butchering' Theft Losses May Evade TCJA Restrictions
• Mega Win for British Snack Company in VAT Dispute
• British Supermarket Owes VAT on Food Bars, U.K. Tribunal Finds
• Nutrition Company Owes VAT on Protein Foods, U.K. Tribunal Finds

Listen to other tax oddities episodes:

• Year-End Collection: Tax Oddities of 2023
• Year-End Collection: Tax Oddities of 2022
• Year-End Collection: Tax Oddities of 2021

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• Emily Hollingsworth: @EmilyHoll9
• Kiarra Strocko: @KiarraStrocko
• David Stewart: @TaxStew
• Tax Notes: @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

Tax Notes chief correspondent Stephanie Soong recaps the latest updates from the OECD’s two-pillar project and highlights what is expected from the organization in 2025. 

Listen to our previous episodes on the two pillars here:

• An Update on Pillar 1 Amount B
• Pillar 1 Amount B: Disagreements and Divides
• Manal Corwin Takes the Helm: Updates on the OECD Tax Reform Plan
• Bringing Order to Chaos? Digital Services Taxes and Pillar 1

For more coverage, read the following in Tax Notes:

• IRS to Propose Regs on OECD Amount B Transfer Pricing Approach
• IRS Wants to Preserve DCL Regime Election Amid Pillar 2 Rules
• OECD Transitional Pillar 2 Tax Peer Review Nearing Completion
• UAE to Introduce OECD-Aligned Domestic Minimum Top-Up Tax
• Australian Senate Approves Package of Global Minimum Tax Bills

Follow us on X:

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

Tony Santiago, founder and president of TaxSearch Inc., discusses the future of tax leadership and his recommendations for tax departments looking to create an effective succession plan.

Listen to our previous episode on tax succession, "Paving the Way for the Next Generation of Tax Professionals."

For additional coverage, read Santiago's articles in Tax Notes:

• Tax Department Leadership: Effective Succession Strategies 
• Best Practices for Recruiting Critical Tax Roles
• Optimizing Tax Talent in Challenging Times
• Evaluating Critical Remote Arrangements in Corporate Tax Departments

Follow us on X:

• David Stewart: @TaxStew
• Tax Notes: @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

A Tax Notes investigation unveiled how money sheltered in offshore insurance investment vehicles has eluded IRS auditors hampered by poor training and silos within the agency.  

Leaked documents obtained by the International Consortium of Investigative Journalists and reviewed by Tax Notes show private placement life insurance structures — a special type of insurance available only to wealthy investors — with millions of dollars set up in offshore tax havens like Belize and the Cayman Islands. 

Three members of the Tax Notes investigations team explain their reporting process, from choosing the topic to final follow-ups. 

If you have a tip for the investigations team, reach them at [email protected] or through the Signal app at 347-731-3183.

For more, check out the team's coverage on private placement life insurance:

• Chance of Changes to Life Insurance ‘Wrappers’ Dims Postelection
• How Offshore Life Insurance Helps Business Owners Minimize Taxes
• High-End Life Insurance Policies Lured Offshore by Relaxed Rules
• Inside How Private Placement Life Insurance Slips Through the Cracks

To hear Senator Wyden's full statement, visit https://www.youtube.com/watch?v=xiez_NnUBZQ.

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• Lauren Loricchio: @LaurenLoricchio
• Chandra Wallace: @ChandraSWallace
• Sarah Paez: @PaezWrites
• Kiarra Strocko: @KiarraStrocko
• David Stewart: @TaxStew
• Tax Notes: @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

In an exclusive sit-down interview with Tax Notes Talk, IRS Commissioner Daniel Werfel discusses his tenure and the agency’s future with major Tax Cuts and Jobs Act provisions expiring next year.

For more coverage, read the following in Tax Notes:

• IRS Is Well Positioned to Handle Tax Bill, Werfel Says
• IRS Council Calls for Public Education About Tax Noncompliance
• IRS to Beef Up Artificial Intelligence Oversight Structure
• Election Results Cast Doubt on Fate of IRS Funding, Direct File
• Werfel Says Agency Is Gearing Up to Weigh In on TCJA Expiration

Follow us on X:

• Ben Valdez: @benmvaldez
• David Stewart: @TaxStew
• Tax Notes: @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

Jānis Taukačs, a partner at Sorainen in Latvia, discusses the Baltic region’s tax priorities, as well as his own professional journey through the world of tax. 

For other episodes from Cape Town, listen to:

• "From Cape Town: A Sit-Down With South Africa's Top Tax Official."
• "From Cape Town: Developing Tax Policy for Developing Nations."

For more about the Sergei Magnitsky story, read David Stewart's article in Tax Notes, "Death of Russian Lawyer Puts Spotlight on Hermitage Tax Fraud."   

For more coverage, read the following in Tax Notes:

• OECD Framework Discussing Permanent Pillar 2 Safe Harbors
• Frustration Persists in OECD Framework Over Pillar 1
• Lithuania Tax Authority Proposes Pillar 2 Implementing Rules
• Latvian Parliament Passes Global Minimum Tax Legislation

Follow us on X:

• David Stewart: @TaxStew
• Tax Notes: @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

Professor Afton Titus of the University of Cape Town explains her view on how the tax initiatives of the OECD and United Nations affect developing nations.

For other episodes from Cape Town, listen to "From Cape Town: A Sit-Down With South Africa's Top Tax Official."

For more coverage, read the following in Tax Notes:

• Trump Win Casts Shadow Over OECD Global Tax Reforms
• OECD Framework Discussing Permanent Pillar 2 Safe Harbors
• Frustration Persists in OECD Framework Over Pillar 1
• U.N. Official Floats Cooperation With OECD on Tax Dispute Issues
• New U.N. Model Tax Treaty Article Is a Win for Developing Countries
• Bilateral Treaty Sourcing Rules Harm Developing Countries, Paper Says

For information about our live Taxing Issues event, visit: https://events.taxanalysts.org/tawebinar112024 

Follow us on X:

• David Stewart: @TaxStew
• Tax Notes: @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

South African Revenue Service Commissioner Edward Kieswetter discusses his tenure leading the agency and the country’s position in the modernization of the international tax system.

For more coverage, read the following in Tax Notes:

• DSTs Could Violate Tax Treaty Obligations, U.N. Official Says
• EU Commission Fully Supports Permanent Pillar 2 Safe Harbor
• OECD Framework Discussing Permanent Pillar 2 Safe Harbors
• Frustration Persists in OECD Framework Over Pillar 1
• U.N. Official Floats Cooperation With OECD on Tax Dispute Issues
• New U.N. Model Tax Treaty Article Is a Win for Developing Countries
• South African Tax Chief Warns Taxing Right Fight Will Intensify

For information about our live Taxing Issues event, visit: https://events.taxanalysts.org/tawebinar112024 

Follow us on X:

• David Stewart: @TaxStew
• Tax Notes: @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

Tax Notes contributing editor Robert Goulder shares his take on the effects of the Foreign Account Tax Compliance Act and common reporting standards on the feasibility of taxing foreign assets.

Listen to our previous episodes on taxing hidden assets:

• The Constitutionality of Penalties on Undeclared Assets
• America the Tax Haven? Exploring the U.S. Trade Deficit

For more coverage, read the following in Tax Notes:

• Trump Vows to End ‘Double Taxation’ of Overseas Citizens
• Court Tells DOJ No Do-Over in Venture Capitalist FBAR Case
• EU, Belgium Say Domestic Bank Secrecy Hinders Tax Transparency
• U.S., Switzerland to Exchange Info Under New FATCA Deal From 2027
• IRS Approves Argentina’s Data Security for FATCA Exchanges
• Transparency Not a Threat to Privacy, Tax Justice Network Says

For information about our live Taxing Issues event, visit: https://events.taxanalysts.org/tawebinar112024 

Follow us on X:

• Bob Goulder: @RobertGoulder
• David Stewart: @TaxStew
• Tax Notes: @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