Tax Notes Talk

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...

House Ways and Means Committee member Steven Horsford, D-Nev., discusses the New Democrat Coalition’s tax priorities and the framework the coalition developed as an alternative to the One Big Beautiful Bill Act. 

Check out our break down of the passed legislation, "The One Big Beautiful Bill Act: What Made the Final Cut?"

For more coverage, read the following in Tax Notes:

• One Big Beautiful Bill Redux Could Be '2 Bi...

Tax Notes Capitol Hill reporters Cady Stanton and Katie Lobosco explore the final version of the One Big Beautiful Bill Act that President Trump signed into law on July 4.  

For more coverage, read the following in Tax Notes:

• Revenge Tax Ghost Looms Over G7’s Pillar 2 Deal
• Trump Tax Bill Brings State Funding Dilemmas, Conformity Choices
• OBBBA Is the Biggest Tax Bill Ever. Why Doesn’t It Feel Like It?
• Trump Got His Tax Bill. Now the ...

Ryan Minnick of the Federation of Tax Administrators discusses how state tax agencies are approaching artificial intelligence and shares insights from the FTA’s upcoming briefing paper on generative AI and its 2024 tax agency survey. 

For more coverage, read the following in Tax Notes: 

• California Tax Agency Ramping Up for Generative AI
• State Tax Administrators Are Studying the Use of Generative AI

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Tax Notes investigations editor Lauren Loricchio discusses Treasury’s information sharing agreement with the Department of Homeland Security and its implications for immigrants. 

Read Loricchio's full story in Tax Notes, "Information Sharing Deal Complicates Immigrant Return Filing."

For more on what's been happening at the IRS, check out our previous episodes:

• Past IRS Commissioners Analyze Agency Changes Unde...

Jonathan Samford and Kevin Klein of the Global Business Alliance discuss the proposed section 899 retaliatory tax and other international tax provisions included in the Senate version of the One Big Beautiful Bill Act. 

For more on the bill, check out our previous episodes:

• In The Zone: Changes to Opportunity Zones in the House Budget Bill
• One Big Beautiful Bill: Breaking Down the House Tax Package
• The House Budget Bill’s Clean Ene...

Jessica Millett of Hogan Lovells discusses the proposed changes to the Opportunity Zone program under the House version of the One Big Beautiful Bill Act and how the Senate might react.

For more on the One Big Beautiful Bill Act, check out our previous episodes:

• One Big Beautiful Bill: Breaking Down the House Tax Package
• The House Budget Bill’s Clean Energy Tax Credit Changes

For more coverage, read the following in Tax N...

Former IRS Commissioners Lawrence Gibbs, John Koskinen, Charles Rettig, and Daniel Werfel share lessons learned from their tenures and predictions for the agency's future under the new administration. 

For the full discussion, check out our Taxing Issues episode, "Reimagining the IRS: A Historic Conversation."

For more coverage, read the following in Tax Notes:

• IRS Clawback Fight Moves to Reconciliation, Appropriati...

Tax Notes Capitol Hill reporters Cady Stanton and Katie Lobosco discuss the final version of the House’s reconciliation bill and what’s next as the legislation heads to the Senate.

Listen to our previous episode on the bill's clean energy credit changes, "The House Budget Bill’s Clean Energy Tax Credit Changes."

For more coverage, read the following in Tax Notes:

• Senate Must Make Tricky Process Decision for Tax Bill...

Jenny Speck with Vinson & Elkins discusses the clean energy tax credits in the House’s One Big Beautiful Bill Act, including last-minute changes to the House Rules Committee’s version. 

For more coverage, read the following in Tax Notes:

• House Advances $3.8 Trillion Tax Bill; Faces Rewrite in Senate
• Democratic Dads Say Tax Bill Would Pass Debt Burden to Kids
• Clean Energy Industry Seeks Edits to Tax Bill
• Analysis: The Future of I...