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    Arts

    Tax Notes Talk

    With Tax Notes Talk, you’ll never miss the latest in tax news and analysis. Tune in to hear experts from around the world weigh in on the issues shaping the world of tax.

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    Copyright: ℗ & © 2020 Tax Notes Talk

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    Latest Episodes:
    Multiple Trust Planning and 199A Regs Nov 09, 2018
    Show notes

    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



    Deciphering the New Loss Limitation Rules Nov 02, 2018
    Show notes

    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




    Brexit: The Tax Implications Oct 26, 2018
    Show notes

    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


    The Taxability of Peer-to-Peer Car Sharing Oct 19, 2018
    Show notes

    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



    ABA Meeting: Key Takeaways Oct 12, 2018
    Show notes

    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
    An Overview of the Proposed SALT Regs Oct 05, 2018
    Show notes

    Amy Hamilton discusses the IRS's proposed regulations addressing workarounds to the cap on state and local tax deductions.

    For additional coverage of the SALT regs, read these articles from Tax Notes:

    • California Governor Vetoes SALT Deduction Cap Workaround
    • New York Coalition to Fight Federal SALT Regulations
    • The Frivolous Challenge to the SALT Deduction Cap
    • Practitioners Urge Caution in Passthrough SALT Cap Planning
    • New Jersey Won't Scrap SALT Cap Workaround, Despite IRS Regs
    • Treasury Receives More Than 1,500 Comments on Proposed SALT Regs
    • Proposed Federal SALT Rules Would Close Private School Donation Strategy
    • IRS Has Plan to Shut Down SALT Workarounds
    Proposed GILTI Regs: The Details Sep 27, 2018
    Show notes

    Andrew Velarde and Alexander Lewis provide an in-depth look into the proposed regs on global intangible low-taxed income.

    Read Tax Notes’ latest coverage of the proposed GILTI regs:

    • Treasury Assuages Some Concern Over GILTI Antiabuse Rule Breadth
    • GILTI Regs Signal Business Interest Limits Might Apply
    • Proposed GILTI Regs Could Result in Taxable Phantom Income
    • Practitioners Bristle at GILTI Antiabuse Provision
    • Practitioners Throw More Shade at GILTI Antiabuse Rules
    • GILTI Regs Focus on Computations, Punt on FTC Issues
    IFA 2018: The Highlights Sep 18, 2018
    Show notes

    Stephanie Johnston, Robert Goulder, and David Stewart highlight the hot topics at the 72nd Congress of the International Fiscal Association recently held in Seoul.

    Check out these stories for coverage of the 2018 IFA Congress:

    • EU Digital Taxation Plan Is ‘Not a Master Thesis’
    • OECD Makes Headway on Long-Term Answers to Tax Digital Economy
    • OECD Finalizing Work to Enlist Digital Platforms to Collect VAT
    • Judicial Oversight Important for GAAR Application, Judge Says
    • Germany Wants Progress on BEPS, Minimum Effective Taxation
    • EU Member States Remain Divided Over Digital Services Tax
    Navigating the Post-Wayfair World Sep 14, 2018
    Show notes

    Paige Jones talks to Jim Ford of Global Tax Management about how retailers are preparing to collect and remit sales and use taxes in the wake of the U.S. Supreme Court's decision in South Dakota v. Wayfair Inc.

    Altera: All You Need to Know Aug 31, 2018
    Show notes

    David Stewart, Kristen Parillo, and Ryan Finley examine the Altera v. Commissioner case — everything leading up to the Ninth Circuit opinion, the withdrawal of the opinion by that court, and the status of the case now.

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