Tax Notes Talk

Tax Notes reporter Sarah Paez breaks down the biggest international tax developments from the annual Congress of the International Fiscal Association in Lisbon, Portugal.

For more coverage, read the following in Tax Notes:

• OECD Plans 2026 Draft on Transfer Pricing Guidelines Revisions
• EU Wants Its U.S. Subsidiaries to Be Subject to Top-Up Tax
• ESG Ratings Don’t Inform Tax Risk, HMRC Official Says
• Pillar 2 Permanent Safe Harbor Talks Focused on Integrity Issues

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• Sarah Paez: @PaezWrites
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

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

Join us at the inaugural Tax Trends Summit in Washington, D.C. presented by Tax Notes and the ABA Tax Section. For more information, visit taxnotes.co/taxtrends25.

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Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes

April Harding, former IRS director of user experience services, discusses her proposed agency modernization plan and the future of IRS digital products. 

For more coverage, read the following in Tax Notes:

• Shutdown Uncertainty Adds to Difficult Year for IRS Employees
• Direct File Derailed by Dissension, Not Performance, Werfel Says
• What's Next for the IRS? Another Overhaul?

Follow us on X:

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

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

Join us at the inaugural Tax Trends Summit in Washington, D.C. presented by Tax Notes and the ABA Tax Section. For more information, visit taxnotes.co/taxtrends25.

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Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes

Karen Kelly, former acting assistant attorney general of the Justice Department Tax Division, discusses the upcoming elimination of the division and how it could affect civil and criminal tax enforcement. 

For more coverage, read the following in Tax Notes:

• House Bill Would Formalize Abolition of DOJ Tax Division
• Tax Community Pushes to Keep DOJ Tax Division Intact
• Idea to Disperse DOJ Tax Lawyers Draws Mixed Initial Reaction

Follow us on X:

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

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

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Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes

Professors David Gamage and Darien Shanske discuss their recent paper, “Money Moves: Taxing the Wealthy at the State Level,” which lays out their argument for a state-level wealth tax.

For more, read Gamage and Shanske's article, coauthored by Professor Brian Galle.

For more coverage, read the following in Tax Notes:

• U.K. Labour Deputy Leader Hopeful Campaigns for Wealth Taxes
• Report on 16,500 Millionaires Quitting U.K. 'May Be Fabricated'
• Tax Justice Network Report Urges Wealth Tax for Climate Finance

Follow us on X:

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

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

***

Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes

Tax Notes contributing editors Robert Goulder and Joseph Thorndike discuss the recent Nvidia deal to export chips to China, and they question its constitutionality and implications. 

For more coverage, read the following in Tax Notes:

• ANALYSIS: The Nvidia Affair: So Now We're Taxing Exports?
• ANALYSIS: Trump’s Nvidia Deal Is Almost Certainly Unconstitutional — Not That It Matters
• White House Eyes Replicating Nvidia Deal for Other Industries
• Nvidia Deal Sparks Dismay From Tax Observers

Follow us on X:

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

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Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes

Former IRS Chief Privacy Officer Kathleen Walters discusses the agency’s data sharing agreement with the Department of Homeland Security, her decision to step down, and life as a working mom.  

For more coverage, read the following in Tax Notes:

• Treasury Looks to Undo Some IRS Resignations
• IRS Posts Thousands of Jobs Amid Workforce Reductions
• IRS Has Answered Immigration Agency's Request for Tax Data

Follow us on X:

• Paige Jones: @PaigeLeeJones
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

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Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes

Tax Notes contributing editor Robert Goulder discusses how Pope Leo XIV’s American citizenship creates a unique tax issue and how the United States may try to avoid taxing the pope.  

For more coverage, read the following in Tax Notes:

• Expats Eye Pope's Tax Woes as Opportunity to Ditch Worldwide Tax
• Analysis: The American Pope and Citizenship-Based Taxation

Follow us on X:

• Robert Goulder: @RobertGoulder
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

**

Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes

Tax Notes contributing editor Ryan Finley discusses the current transfer pricing landscape, including where things stand in the Facebook and Coca-Cola cases. 

For more coverage, read the following from Finley in Tax Notes:

• Analysis: The CUT Method: It's Not What It Used to Be
• Analysis: The CUT Method: Same as It Ever Was?
• Analysis: On Periodic Adjustments, Facebook Opinion Suggests A Middle Road
• Analysis: For the IRS, Facebook Is a Reminder to Stick to the Script
• Analysis: Medtronic II: Do the Transfer Pricing Regs Swallow Themselves?
  
  

Follow us on X:

• Ryan Finley: @RyanMFinley
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

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Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes

Ellen Aprill of UCLA discusses the legal battle between Harvard and the Trump administration over the university's tax-exempt status and the recourses that an exempt organization may have if its status is revoked.

For more, read Aprill's article, "Revoking Tax Exemption for Pursuit of DEI and Other Alleged Forms of Discrimination."

For more coverage, read the following in Tax Notes:

• Flood of New Briefs Support Ending Johnson Amendment Restrictions
• Senate Dems Seek Probe of Trump's Challenge to Harvard's Exemption
• Trump Questions Harvard's Tax-Exempt Status
  
  

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
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes

Steve Kralik of Armanino discusses the One Big Beautiful Bill Act’s implications for state tax, including the new version of the SALT cap and how states may conform to the changes. 

For more coverage, read the following in Tax Notes:

• Colorado Faces $1.2 Billion Revenue Loss From OBBBA Provisions
• California Advances Conformity Update Bill Without OBBBA Provisions
• Trump Tax Bill Brings State Funding Dilemmas, Conformity Choices

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
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes