Tax Notes Talk

Tax Notes IRS reporter Benjamin Valdez provides an update on the IRS’s recent staffing developments and how they may affect filing season.  

Check out our most recent episode on the IRS, "Trump's Hiring Freeze and the IRS."

For more coverage, read the following in Tax Notes:

• IRS Rollout of In-Person Work Faces Obstacles
• Treasury, IRS Still Finalizing Next Staff Reductions, Krause Says
• IRS to Pause Technology Modernization Work
• Trump Replaces Acting IRS Chief Counsel
• Ousted IRS Human Capital Officer Pushed Back on Firings, DOGE
• Former IRS Officials Warn of Consequences to Staff Cuts

Follow us on X:

• Ben Valdez: @BenMValdez
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

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

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes

Melissa Wiley of Kostelanetz LLP provides an update on the Corporate Transparency Act’s legal status after Treasury announced it would not enforce penalties against domestic companies. 

Listen to our previous episodes on the CTA:

• The Corporate Transparency Act: Recent Challenges and Confusion
• Navigating the Corporate Transparency Act

For more coverage, read the following in Tax Notes:

• Corporate Transparency Act Found to Violate Fourth Amendment
• Treasury Announces Shift in CTA Focus to Foreign Companies
• FinCEN Pauses Beneficial Ownership Reporting Penalties

Follow us on X:

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

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

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes

In the third of a three-part series, Damien Martin and Tony Nitti of EY discuss their top tax cases from 2024, focusing on two C corp cases: Ju et al v. United States and Stead v. Commissioner. 

Watch the first two parts of the series: 

• Top Tax Cases of 2024, Part 1: Partnerships
• Top Tax Cases of 2024, Part 2: S Corporations

Follow us on X:

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

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

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Video Editors: Jordan Parrish, Chris Trigo, Peyton Rhodes

In the second of a three-part series, Damien Martin and Tony Nitti of EY discuss their top tax cases from 2024, focusing on two S corp cases: Maggard v. Commissioner and Estate of Thomas Fry et al v. Commissioner. 

Watch the first part of the series, "Top Tax Cases of 2024, Part 1: Partnerships."

For more coverage, read the following in Tax Notes:

• Tax Court Rejects Engineer’s S Corp Dissolution Defense
• ABA Pushes for More Guidance on S Corp Reorganizations

Follow us on X:

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

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

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Video Editors: Jordan Parrish, Chris Trigo, Peyton Rhodes

In the first of a three-part series, Damien Martin and Tony Nitti of EY discuss their top tax cases from 2024, focusing on two partnership cases: Denham Capital Management LP v. Commissioner and Surk LLC v. Commissioner. 

For more coverage, read the following in Tax Notes:

• DOJ Touts Tax Court Win on Limited Partner Exception
• Tax Pros Weigh Impact of Ruling on IRS Basis Calculation Method

Follow us on X:

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

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

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Video Editors: Jordan Parrish, Chris Trigo, Peyton Rhodes

Tax Notes contributing editor and historian Joseph J. Thorndike discusses President Trump’s referral to “the forgotten man” and how the phrase connects to a conservative case for taxing the rich. 

Read Thorndike's article in Tax Notes, "The Too-Well-Remembered Man: A Conservative Case for Taxing the Rich."

For more coverage, read the following in Tax Notes:

• Bye-Bye Round Numbers, Hello Rate Tweaks for Rescored TCJA Bill
• Movement on Trump Tax Proposals Is Reconciliation Wild Card
• Moores' Counsel Says Case Signals Court Is Not Open to Novel Taxes

Follow us on X:

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

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

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes

Robert Kerr, formerly with the IRS and now with Kerr Consulting, discusses the recent federal hiring freeze and buyout offer and speculates how they may affect the IRS.

Listen to our previous episode on how Trump's executive orders relate to international tax, "Former U.S. OECD Negotiator Talks Trump's Global Tax Impact."

For more coverage, read the following in Tax Notes:

• IRS Claims Filing Season Staff Are Exempt From Buyout
• Fiscal 2026 Budget Cycle Could Be Critical for IRS Funding Path
• Federal Hiring Freeze Quickly Hits Prospective IRS Attorneys

Follow us on X:

• Ben Valdez: @BenMValdez
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

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

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes

Scott Levine, former Treasury deputy assistant secretary for international tax affairs, discusses President Trump’s executive order on the OECD’s global tax deal and its potential impact on the two-pillar project. 

Listen to our previous episodes on the two pillars here:

• Making Progress: Updates on the OECD Tax Reform Plan
• 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

For more coverage, read the following in Tax Notes:

• Official Highlights Importance of Amount B Amid Undecided Future
• Economist Warns U.S. Rejection of Global Minimum Tax Hurts EU
• House Republicans Reintroduce Anti-Pillar 2 Legislation
• EU Laments Trump's Disregard for OECD's Global Tax Plan

Follow us on X:

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

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

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes

Tax Notes investigations editor Lauren Loricchio discusses security concerns regarding tax software platforms’ data-sharing practices.   

Read Loricchio's article, "Monetization of Tax Data Sparks Concerns About Security."

For additional coverage, read the following articles in Tax Notes:

• Taxpayer Data Leak Investigations Rarely Lead to Prosecutions
• ProPublica Data Leak Lawsuit Ends in Settlement
• IRS Discussing Response to Data Sharing by Tax Prep Companies

Follow us on X:

• Lauren Loricchio: @LaurenLoricchio
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

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

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes

Lili Martin-Mashburn of Morris, Manning & Martin provides an update on where the Corporate Transparency Act stands in light of the recent litigation regarding its constitutionality.

Listen to our previous episode on the CTA, "Navigating the Corporate Transparency Act."

For more coverage, read the following in Tax Notes:

• Once Again, District Court Finds CTA Likely Unconstitutional 
• 25 States Side With Businesses in Transparency Act Challenges
• Fifth Circuit Puts Corporate Transparency Act Back on Hold

Follow us on X:

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

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

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes