Tax Notes Talk

Professors Jeremy Bearer-Friend and Sarah Polcz discuss their recent paper, “Sharing the Algorithm: The Tax Solution to Generative AI,” which outlines their proposal for taxing generative AI companies.

For more, read Bearer-Friend and Polcz's article.

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

Professor Andrea Campbell, author of Taxation and Resentment: Race, Party, and Class in American Tax Attitudes, discusses why Americans' beliefs about taxes often don’t align with the specific tax policies they support.

For more on Taxation and Resentment, you can read Joseph Thorndike's book review here: "ANALYSIS: Why Do Americans Ignore Their Self-Interest When It Comes to Taxes?"

If you're interested in h...

Damien Martin and Tony Nitti of EY discuss the second three of their top six tax cases of 2025, focusing on what qualifies as a deduction in Savage v. Commissioner, Kelly v. Commissioner, and Weston v. Commissioner.

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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

This episode is sponsored by ...

Damien Martin and Tony Nitti of EY analyze the first three of their top six tax cases from 2025, focusing on what constitutes income in CF Headquarters Corp. v. Commissioner, Franklin v. Commissioner, and Feige v. Commissioner.

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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

This episode is s...

Philip Hwang, national chair of the Taxpayer Advocacy Panel, discusses the issues the IRS and return preparers could face this filing season following the passage of the One Big Beautiful Bill Act. 

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

• IRS Prepared to Meet Service, Collection Goals, Bisignano Says
• Proposed IRS Funding Cut Draws Concern From Tax Watchers
• IRS Sets Filing Season Start Date Amid Lofty Refund Expectati...

Jaye Calhoun of Kean Miller discusses key tax issues that states will likely address in 2026, including One Big Beautiful Bill Act provisions and the adoption of artificial intelligence tools. 

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

• Iowa DOR Issues Withholding Guidance on OBBBA Tax Deductions
• U.S. Chamber Backs Florida Bid to Challenge California Apportionment Rule
• States to Face Budget, Tax Policy Questions in 2026...

Tax Analysts Chief Operating Officer Jeremy Scott reviews the 2025 developments in U.S. tax legislation and speculates what may lie ahead in 2026.

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

• These Expiring Tax Provisions Could Get Renewed in 2026
• New Deficit Projections to Hinge on Giant Tax Bill, Tariffs
• More Clean Energy Credits Are Set to Expire in 2026 Under OBBBA
• Tips and Overtime Reporting Expected to Test Employers...

Tax Notes reporters recap some of the most memorable stories they encountered in 2025, from the establishment of a "crypto church" to how the "no tax on tips" provision may apply to certain professions. 

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

• Will IRS Know Pornography When It Sees It for Tips Deduction?
• Pass Go, Collect Millions: Hasbro to Get Tax Breaks for Boston HQ
• Marital Discord Is No Defens...

Vanessa Williamson, author of The Price of Democracy, discusses her argument that the history of American fights over fiscal fairness reveals a connection between taxation and democratic power.

For more on The Price of Democracy, you can read Joseph Thorndike's book review here: "ANALYSIS: Democracy Comes With a Bill Attached: A Tax-Centered History of America."

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Credits
Host: David D. Stewart
Executive Produc...

Tax Notes reporters discuss updates on the biggest tax issues of the year, including the expiring Affordable Care Act credit and the Trump administration's recent tariff and trade announcements.

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

• Senate Set to Reject Dueling Bills, Leaving ACA Credit in Limbo
• New Guidance Provided on Expanded HSA Eligibility
• Trump Threatens Mexico With Tariffs Over Texas Water Spat
• House GOP...

Trudy Muscat of Deloitte Malta discusses Malta's changing international tax landscape, including its adoption of the two-pillar system and recently implemented transfer pricing rules. 

For more episodes from Lisbon, listen to:

• From Lisbon: The Search for Consensus on International Tax
• From Lisbon: The Future of International Tax Cooperation
• From Lisbon: Portuguese Tax Administration in the Digital Age
• From Lisbon: Highlights Fr...

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
<...

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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This epi...

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 ...