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Tax Notes chief correspondent Stephanie Soong recaps the latest updates from the OECD’s two-pillar project and highlights what is expected from the organization in 2025.
An Update on Pillar 1 Amount BPillar 1 Amount B: Disagreements and DividesManal Corwin Takes the Helm: Updates on the OECD Tax Reform PlanBringing Order to Chaos? Digital Services Taxes and Pillar 1
Listen to our previous episodes on the two pillars here:
IRS to Propose Regs on OECD Amount B Transfer Pricing ApproachIRS Wants to Preserve DCL Regime Election Amid Pillar 2 RulesOECD Transitional Pillar 2 Tax Peer Review Nearing CompletionUAE to Introduce OECD-Aligned Domestic Minimum Top-Up TaxAustralian Senate Approves Package of Global Minimum Tax Bills
For more coverage, read the following in Tax Notes:
Stephanie Soong: @StephanieSoongDavid Stewart: @TaxStewTax Notes: @TaxNotes
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Tony Santiago, founder and president of TaxSearch Inc., discusses the future of tax leadership and his recommendations for tax departments looking to create an effective succession plan.
Tax Department Leadership: Effective Succession Strategies Best Practices for Recruiting Critical Tax RolesOptimizing Tax Talent in Challenging TimesEvaluating Critical Remote Arrangements in Corporate Tax Departments
Listen to our previous episode on tax succession, "Paving the Way for the Next Generation of Tax Professionals."
For additional coverage, read Santiago's articles in Tax Notes:
David Stewart: @TaxStewTax Notes: @TaxNotes
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A Tax Notes investigation unveiled how money sheltered in offshore insurance investment vehicles has eluded IRS auditors hampered by poor training and silos within the agency.
Leaked documents obtained by the International Consortium of Investigative Journalists and reviewed by Tax Notes show private placement life insurance structures — a special type of insurance available only to wealthy investors — with millions of dollars set up in offshore tax havens like Belize and the Cayman Islands.
Three members of the Tax Notes investigations team explain their reporting process, from choosing the topic to final follow-ups.
If you have a tip for the investigations team, reach them at [email protected] or through the Signal app at 347-731-3183.
Chance of Changes to Life Insurance ‘Wrappers’ Dims PostelectionHow Offshore Life Insurance Helps Business Owners Minimize TaxesHigh-End Life Insurance Policies Lured Offshore by Relaxed RulesInside How Private Placement Life Insurance Slips Through the Cracks
For more, check out the team's coverage on private placement life insurance:
Lauren Loricchio: @LaurenLoricchioChandra Wallace: @ChandraSWallaceSarah Paez: @PaezWritesKiarra Strocko: @KiarraStrockoDavid Stewart: @TaxStewTax Notes: @TaxNotes
To hear Senator Wyden's full statement, visit https://www.youtube.com/watch?v=xiez_NnUBZQ.
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In an exclusive sit-down interview with Tax Notes Talk, IRS Commissioner Daniel Werfel discusses his tenure and the agency’s future with major Tax Cuts and Jobs Act provisions expiring next year.
IRS Is Well Positioned to Handle Tax Bill, Werfel SaysIRS Council Calls for Public Education About Tax NoncomplianceIRS to Beef Up Artificial Intelligence Oversight StructureElection Results Cast Doubt on Fate of IRS Funding, Direct FileWerfel Says Agency Is Gearing Up to Weigh In on TCJA Expiration
For more coverage, read the following in Tax Notes:
Ben Valdez: @benmvaldezDavid Stewart: @TaxStewTax Notes: @TaxNotes
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Jānis Taukačs, a partner at Sorainen in Latvia, discusses the Baltic region’s tax priorities, as well as his own professional journey through the world of tax.
"From Cape Town: A Sit-Down With South Africa's Top Tax Official.""From Cape Town: Developing Tax Policy for Developing Nations."
For other episodes from Cape Town, listen to:
OECD Framework Discussing Permanent Pillar 2 Safe HarborsFrustration Persists in OECD Framework Over Pillar 1Lithuania Tax Authority Proposes Pillar 2 Implementing RulesLatvian Parliament Passes Global Minimum Tax Legislation
For more about the Sergei Magnitsky story, read David Stewart's article in Tax Notes, "Death of Russian Lawyer Puts Spotlight on Hermitage Tax Fraud."
For more coverage, read the following in Tax Notes:
David Stewart: @TaxStewTax Notes: @TaxNotes
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Professor Afton Titus of the University of Cape Town explains her view on how the tax initiatives of the OECD and United Nations affect developing nations.
Trump Win Casts Shadow Over OECD Global Tax ReformsOECD Framework Discussing Permanent Pillar 2 Safe HarborsFrustration Persists in OECD Framework Over Pillar 1U.N. Official Floats Cooperation With OECD on Tax Dispute IssuesNew U.N. Model Tax Treaty Article Is a Win for Developing CountriesBilateral Treaty Sourcing Rules Harm Developing Countries, Paper Says
For other episodes from Cape Town, listen to "From Cape Town: A Sit-Down With South Africa's Top Tax Official."
For more coverage, read the following in Tax Notes:
For information about our live Taxing Issues event, visit: https://events.taxanalysts.org/tawebinar112024Follow us on X:
David Stewart: @TaxStewTax Notes: @TaxNotes
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South African Revenue Service Commissioner Edward Kieswetter discusses his tenure leading the agency and the country’s position in the modernization of the international tax system.
DSTs Could Violate Tax Treaty Obligations, U.N. Official SaysEU Commission Fully Supports Permanent Pillar 2 Safe HarborOECD Framework Discussing Permanent Pillar 2 Safe HarborsFrustration Persists in OECD Framework Over Pillar 1U.N. Official Floats Cooperation With OECD on Tax Dispute IssuesNew U.N. Model Tax Treaty Article Is a Win for Developing CountriesSouth African Tax Chief Warns Taxing Right Fight Will Intensify
For more coverage, read the following in Tax Notes:
For information about our live Taxing Issues event, visit: https://events.taxanalysts.org/tawebinar112024Follow us on X:
David Stewart: @TaxStewTax Notes: @TaxNotes
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Tax Notes contributing editor Robert Goulder shares his take on the effects of the Foreign Account Tax Compliance Act and common reporting standards on the feasibility of taxing foreign assets.
The Constitutionality of Penalties on Undeclared AssetsAmerica the Tax Haven? Exploring the U.S. Trade Deficit
Listen to our previous episodes on taxing hidden assets:
Trump Vows to End ‘Double Taxation’ of Overseas CitizensCourt Tells DOJ No Do-Over in Venture Capitalist FBAR CaseEU, Belgium Say Domestic Bank Secrecy Hinders Tax TransparencyU.S., Switzerland to Exchange Info Under New FATCA Deal From 2027IRS Approves Argentina’s Data Security for FATCA ExchangesTransparency Not a Threat to Privacy, Tax Justice Network Says
For more coverage, read the following in Tax Notes:
For information about our live Taxing Issues event, visit: https://events.taxanalysts.org/tawebinar112024Follow us on X:
Bob Goulder: @RobertGoulderDavid Stewart: @TaxStewTax Notes: @TaxNotes
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Monisha Santamaria and Nick Tricarichi of KPMG discuss the scope of the latest guidance on the corporate alternative minimum tax and its impact on tax and accounting professionals.
Listen to our previous episode on CAMT: Navigating New Guidance on the Corporate Alternative Minimum TaxFor more coverage, read the following in Tax Notes:
Exempt Orgs Get Temporary Break From Filing Corporate AMT FormCorrections Coming for Corporate AMT Proposed RegsTreasury Downplays FTC Timing Concerns in Corporate AMT RegsMore Corporate AMT Safe Harbors Are on the TableAnalysis: CAMTyland Adventures, Part V: Coping With CAMTyland Grief
Chandra Wallace: @ChandraSWallaceDavid Stewart: @TaxStewTax Notes: @TaxNotes
For information about our live Taxing Issues event, visit: https://events.taxanalysts.org/tawebinar112024
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Tax Notes White House reporter Alexander Rifaat discusses the tax policies proposed by Vice President Kamala Harris and former President Trump.
Trump Proposes Tax Write-Off for Generator PurchasesTrump Proffers Tax Incentives for Car Owners, ManufacturersTrump’s Plan Would Swell Deficit More Than Harris’s, Study SaysNo Indication Vance Will Release Tax ReturnsHarris Proposes New Manufacturing Tax CreditUnrealized Capital Gains Proposal Faces Uncertain PathHarris Says ‘Trump Tax’ Would Cost Americans $4,000 AnnuallyHarris Held Talks With Union Before Making Tip Pledge
For more coverage, read the following in Tax Notes:
Alexander Rifaat: @AlexRifaatDavid Stewart: @TaxStewTax Notes: @TaxNotes
Audio clips obtained from C-SPAN.
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Tax Notes contributing editor Robert Goulder discusses the history of foreign bank account reporting penalties and how two recent court cases could affect the FBAR regime.
For more coverage, read the following in Tax Notes:
Jury Finds Professor’s FBAR Failures WillfulFBAR Penalty Circuit Split Has Potential for Supreme Court ReviewSchwarzbaum FBAR Penalty Dispute Results in Circuit SplitCourt Tells DOJ No Do-Over in Venture Capitalist FBAR CaseNinth Circuit Approves Prejudgment Interest for FBAR Penalties
Bob Goulder: @RobertGoulderDavid Stewart: @TaxStewTax Notes: @TaxNotes
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Professors Kenneth Austin and Hillel Nadler discuss the policies that they believe make the United States a tax haven, and the resulting effects on the economy.
Bad Credit: A Look at Switzerland’s Bank SecrecyLet’s Talk Tax Havens: The EU Blacklist and the Pandora Papers
For more, read Nadler and Austin's article in Tax Notes, "America the Tax Haven and Its Trade Deficits."
Listen to more Tax Notes Talk episodes about tax havens:
EU to Remove Antigua and Barbuda From Tax BlacklistResearchers Try to Quantify Firms’ Use of Tax Havens After TCJABEPS Activity May Have Declined in Tax Havens, OECD ReportsMontana DOR Amends Code to Remove Tax Haven LanguageThe EU Tax Blacklist: A Six-Year Journey Toward Compliance
For more coverage, read the following in Tax Notes:
David Stewart: @TaxStewTax Notes: @TaxNotes
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Tax Notes contributing editor Nana Ama Sarfo discusses methane-related tax policy and how it might lead to future taxation of greenhouse gas emissions.
For more on taxing greenhouse gases, listen to Is Carbon Pricing the Best Way to Mitigate Climate Change?
For additional coverage, read Sarfo's analysis in Tax Notes: The Future of Carbon Taxes Could Lie in MethaneFollow us on X:
Nana Ama Sarfo: @nanaama_sarfoDavid Stewart: @TaxStewTax Notes: @TaxNotes
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Tax Notes contributing editor Ryan Finley breaks down the EU Court of Justice’s recent ruling that Ireland granted €13 billion of unlawful state aid to Apple and its implications for state aid analysis.
For more coverage, read the following in Tax Notes:
Irish Finance Minister Defends Tax System After Apple DecisionCJEU Reinstates €13 Billion State Aid Decision Against AppleFollow us on X:
Ryan Finley: @ryanmfinleyDavid Stewart: @TaxStewTax Notes: @TaxNotes
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Alan McLean, chair of the tax committee at Business at OECD, discusses the developments in the international business tax world during his tenure and the committee’s priorities.
OECD Targets Country Benefits That May Weaken Pillar 2 RulesBusinesses Call for Central Platform for Global Minimum Tax DataGLOBE Permanent Safe Harbor Idea May Boost EU Competitiveness
Listen to our episode with Will Morris, former chair of the tax committee, here: The Tax Diplomat: Reflections From Former BIAC Tax Chair
For more coverage, read the following in Tax Notes:
Stephanie Soong: @StephanieSoongDavid Stewart: @TaxStewTax Notes: @TaxNotes
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Do you have questions about tax policy in the 2024 election? Submit your questions here.
Congress Can Maintain IRS Rulemaking AuthorityWhat About Vague ‘Delegated’ Tax Regulations?
Steve Rosenthal of the Urban-Brookings Tax Policy Center and Don Susswein of RSM discuss how Congress should handle agency delegation following the Loper Bright decision.
For more from Rosenthal and Susswein, read the following:
DOJ, FedEx Contest Loper Bright’s Effect in Offset Earnings CaseLoper Bright Casts Doubt on SECA Guidance Plan, Tax Pros Say
For additional coverage, read the following articles in Tax Notes:
David Stewart: @TaxStewTax Notes: @TaxNotes
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Do you have questions about tax policy in the 2024 election? Submit your questions here.
Tax Extenders Menu Heavy With Energy, Business Tax BreaksTax Package Could Be Useful Lame-Duck Launching PointLengthy Tax Extender Wish List Awaits Lame-Duck SessionHouse GOP Taxwriters Warn of Impacts From Letting TCJA ExpireTrump Makes Murky Claim of Quadrupled Taxes if TCJA Expires
Tax Notes Capitol Hill reporters Cady Stanton and Doug Sword assess the tax policy items on Congress’s slate this fall, from IRS funding to TCJA extenders, and the potential implications of the upcoming elections.
For additional coverage, read these articles in Tax Notes:
Cady Stanton: @cady_stantonDoug Sword: @doug_swordDavid Stewart: @TaxStewTax Notes: @TaxNotes
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Javiera Moraga Valverde, a Chilean lawyer and U.S. law firm associate, discusses her research on how tax systems can harm women via gender-neutral tax policies and shares potential solutions.
Gender Equality, Tax, and the PandemicRace-Based Poll Taxes and 20th-Century DiscriminationExamining Treasury’s Review of Racial Bias in the U.S. Tax CodeIs IRS Tax Enforcement Colorblind?State Tax Authority and Native Americans: Complex and ConvolutedWealth, Inequality, and Taxes in the U.S.Feminism and the Tax CodeTaxes and the LGBTQ CommunityAddressing Racial Inequity in State and Local Tax PolicyThe Tax Code and Economic Justice in AmericaHow Racial Diversity Shaped U.S. International Tax Policy
For more, read Moraga Valverde's article in Tax Notes, "Tax Policy: Is Gender Neutrality Enough?"
Listen to more Tax Notes Talk episodes from our critical tax theory series:
Caitlin Mullaney: @MullaneyWritesDavid Stewart: @TaxStewTax Notes: @TaxNotes
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Sarah Lora of Lewis & Clark Law School discusses the personal exemption after the Tax Cuts and Jobs Act and the implications for immigrant families with nonresident dependents.
Robert Goulder: @RobertGoulderDavid Stewart: @TaxStewTax Notes: @TaxNotes
For more, read Lora's paper, "Righting Tax Wrongs for Immigrants."
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Leslie McLean, director of the low-income taxpayer clinic at DNA-People’s Legal Services, discusses the barriers Navajo Nation members face when filing their taxes and attempting to claim credits.
Legislation, Outreach Could Help Tribal Taxpayers Access Tax CreditsScarce Resources Leave Navajo Nation With Few Tax Options
Listen to the first episode in this series, "The Tax Challenges of the Navajo Nation, Part 1."
Read Investigations Editor Lauren Loricchio's series:
W&M Advances Tribal Child Support Enforcement BillInside the IRS Representation Roadblock Facing Navajo Nation
For additional coverage, read the following articles in Tax Notes:
Lauren Loricchio: @LaurenLoricchioDavid Stewart: @TaxStewTax Notes: @TaxNotes
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