Tax Notes Talk

Juan Manuel Vázquez of Loyens & Loeff discusses the evolving international tax agenda, including ongoing pillar 2 negotiations and taxing the digital economy.

For more episodes from Lisbon, listen to:

• From Lisbon: The Future of International Tax Cooperation
• From Lisbon: Portuguese Tax Administration in the Digital Age
• From Lisbon: Highlights From the 2025 IFA Congress

For related tax news, read the following in Tax Notes:

Tax Notes reporters Cady Stanton and Benjamin Valdez discuss the tax credit debate that led to the government shutdown and the potential effects on the IRS and the 2026 filing season. 

For related tax news, read the following in Tax Notes:

• Democrats Say It's Too Late for Any ACA Credit Alternative
• Shutdown May Hinder Filing Season Timeline, Former IRS Chiefs Say
• Republican Leaders Harden Stance Against ACA Tax Credit

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Tax Notes managing legal reporter Caitlin Mullaney explores the Supreme Court’s oral arguments in V.O.S. Selections and Learning Resources and predicts whether the Court will strike down President Trump’s tariffs. 

For related tax news, read the following in Tax Notes:

• Michigan Agencies Forecast Tariff Impacts on Prices, Jobs
• Supreme Court Justices Question Trump's IEEPA Tariffs
• Trump-Xi Summit Yields Lower Tariffs All Around
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Carolyn Schenck, former IRS national fraud counsel, shares insights from decades at the agency, including her pioneering role and her recent move to private practice. 

For related tax news, read the following in Tax Notes:

• Fresh Look at Exempt Orgs Could Be Good, Former CI Employee Says
• Move to Direct IRS CI at Left-Leaning Groups Is Questioned
• ‘Tax Enforcement Is Not Dead,’ Departing IRS Fraud Counsel Says

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Elisângela Rita, a former member of the U.N. Committee of Experts on International Cooperation in Tax Matters, discusses her career in international tax and the evolution of U.N. global tax convention discussions. 

For more episodes from Lisbon, listen to:

• From Lisbon: Portuguese Tax Administration in the Digital Age
• From Lisbon: Highlights From the 2025 IFA Congress

For related tax news, read the following in Tax Notes:

• U....

Portuguese Tax and Customs Authority General Director Helena Alves Borges discusses the agency’s modernization efforts and preparation for pillar 2. 

For more episodes from Lisbon, listen to "From Lisbon: Highlights From the 2025 IFA Congress."

For more tax news, read the following in Tax Notes:

• More Countries Still Considering Amount B Adoption
• OECD Building Out Work on AI Usage in Tax Administration
• EU Wants Its U.S. Sub...

Tax Notes contributing editor Robert Goulder discusses the upcoming oral arguments before the Supreme Court on the validity of the Trump administration's recent reciprocal tariffs and speculates on the Court's reaction.

For more tax news and analysis, read the following in Tax Notes:

• Nonprofits Urge SCOTUS to Side With Trump Admin in Tariff Dispute
• President Can Impose Tariffs Under IEEPA, Admin Tells SCOTUS
• ANALYSIS: V.O...

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 ...

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...

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

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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 ...

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 Oth...

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

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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

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• Robert Goulder: @RobertGoulder
• David Stewa...

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 ...

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 ...

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

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Alan Cole of the Tax Foundation discusses the international tax provisions in the One Big Beautiful Bill Act and what may be next for negotiations on a global tax framework.  

For more on international tax and the OBBBA, check out our previous episode, "International Tax in the Reconciliation Bill: House Versus Senate."

For more coverage, read the following in Tax Notes:

• Tax Pros Hope for Regs to Resolve One-Month Deferr...

House Ways and Means Committee member Adrian Smith, R-Neb., discusses the One Big Beautiful Bill Act’s accomplishments and what could be next for Congress on tax. 

Check out our interview with Rep. Horsford, "House Taxwriter Talks Democratic Priorities, Responds to OBBBA."

For more coverage, read the following in Tax Notes:

• Lawyers Predict Reconciliation Bill Tax Controversies
• House Appropriators Would Cut IRS Beyond Whit...