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Episodes

International Taxation Conference 2018: A View From India

12/7/2018
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David Stewart talks to Porus Kaka at the International Taxation Conference in Mumbai about various tax issues, including India's new permanent establishment concept, taxation of the digital economy, and the effects of the Tax Cuts and Jobs Act. For related coverage, read these articles in Tax Notes: India’s Tax Chief: Digital Taxation Needs Fair Allocation RulesIndia’s New PE Scheme Limited by Unanswered QuestionsIndia Seeks Input on Digital PE for Taxing Foreign CompaniesIndia's...

Duration:00:12:18

Beyond Wayfair: The Fallout

11/30/2018
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Jad Chamseddine and Paul Jones discuss the Wayfair decision and the long-term implications for state and foreign taxes. Listen to previous episodes on Wayfair: Navigating the Post-Wayfair WorldU.S. Supreme Court Overturns QuillFor additional coverage, read these articles in Tax Notes: Texas Bill Would Provide Statewide Local Tax Rate for Remote SellersWayfair Settlement Is a Missed OpportunitySouth Dakota and Wayfair Litigants Reach SettlementCalifornia Looks to Follow South Dakota on...

Duration:00:18:17

Amazon Chooses HQ2 Locations

11/22/2018
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Lauren Loricchio provides an update on Amazon's choice of two HQ2 locations: Northern Virginia and the borough of Queens in New York City. For more coverage in Tax Notes, read: Louisville Won't Release HQ2 Bid, Despite Amazon Announcement Amazon's New York City HQ2 Site Eligible for Federal Tax BreaksGeorgia First Also-Ran to Reveal Incentives Offered to AmazonAmazon to Split HQ2 Between New York City, Northern VirginiaGroup Slams Reports of Two Amazon HQ2s as 'Bait and Switch'Bezos Will...

Duration:00:06:43

The Midterm Elections: Implications for Tax Policy

11/16/2018
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A roundup of the November 6 midterm election results. Asha Glover and Stephen Cooper discuss what changes to look for in the new Congress, including the makeup of the House Ways and Means Committee and the tax agendas. Paul Jones and Lauren Loricchio discuss the results in the state gubernatorial races as well as the tax ballot measures approved by state voters. For more coverage in Tax Notes, see: Senators Agree on IRS Reform, Extenders as Lame-Duck PrioritiesBrady Eyes Dozens of TCJA...

Duration:00:30:39

Multiple Trust Planning and 199A Regs

11/9/2018
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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 ChallengesCreating Just One Trust for the 199A Deduction? Think AgainNon-Grantor Trusts Still Useful in TCJA PlanningIRS Drops Hammer on 199A, SALT Cap WorkaroundsIRS Likely to Trounce 199A Trust Planning Strategy

Duration:00:12:26

Deciphering the New Loss Limitation Rules

11/2/2018
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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 RadarNew Loss Limitation Hard to Calculate, Interpret With Other Rules

Duration:00:06:09

Brexit: The Tax Implications

10/26/2018
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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 BrexitU.K. Backs Customs Agents Facing Brexit Capacity ChallengeEU, U.K. Leaders Willing to Extend Brexit Transition PeriodBrexit Talks at Impasse Over Customs Backstop ProposalEU Proposes 'Least Intrusive' Customs, VAT Checks After BrexitThe U.K. Can’t Afford to Become a Tax Haven, Says Labour PoliticianEU...

Duration:00:28:39

The Taxability of Peer-to-Peer Car Sharing

10/19/2018
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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 PlanStates Look to Tax the Car-Sharing IndustryAirbnb and the Sharing Economy

Duration:00:14:12

ABA Meeting: Key Takeaways

10/12/2018
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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 CompletionU.S. Antiabuse Rules, Imperfect International Tax Regs ComingTransition Tax Guidance Will Extend Transfer Agreement Due Date'Guideposts’...

Duration:00:10:13

An Overview of the Proposed SALT Regs

10/5/2018
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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 WorkaroundNew York Coalition to Fight Federal SALT RegulationsThe Frivolous Challenge to the SALT Deduction CapPractitioners Urge Caution in Passthrough SALT Cap PlanningNew Jersey Won't Scrap SALT Cap Workaround, Despite IRS RegsTreasury Receives...

Duration:00:08:41

Proposed GILTI Regs: The Details

9/27/2018
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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 BreadthGILTI Regs Signal Business Interest Limits Might ApplyProposed GILTI Regs Could Result in Taxable Phantom IncomePractitioners Bristle at GILTI Antiabuse ProvisionPractitioners Throw More Shade at GILTI Antiabuse RulesGILTI Regs Focus on...

Duration:00:16:22

IFA 2018: The Highlights

9/18/2018
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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 EconomyOECD Finalizing Work to Enlist Digital Platforms to Collect VATJudicial Oversight Important for GAAR Application, Judge SaysGermany Wants Progress on BEPS,...

Duration:00:25:47

Navigating the Post-Wayfair World

9/14/2018
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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.

Duration:00:28:44

Altera: All You Need to Know

8/31/2018
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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.

Duration:00:13:25

Proposed 199A Regs: An In-Depth Overview

8/17/2018
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David Stewart and Eric Yauch delve into the details of the proposed regulations on the passthrough deduction under section 199A.

Duration:00:15:50

Treasury-OMB Tax Reg Agreement

8/10/2018
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Jonathan Curry discusses the details of the new agreement between the Treasury Department and the Office of Management and Budget over authority to review tax regulations.

Duration:00:15:43

State Responses to the TCJA

7/27/2018
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State Tax Notes Chief Correspondent Amy Hamilton examines the impact of federal tax reform on the states and how states are responding legislatively to the Tax Cuts and Jobs Act.

Duration:00:13:00

Transfer Pricing Under the TCJA

7/13/2018
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David Stewart and Ryan Finley discuss whether the Tax Cuts and Jobs Act will finally end the IRS's poor litigation record in transfer pricing cases.

Duration:00:10:25

TCJA: 6 Months Later

6/29/2018
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Tax Notes Today Editor in Chief Brett Ferguson discusses where things are with the Tax Cuts and Jobs Act now that it's been six months since the law was enacted.

Duration:00:08:28

U.S. Supreme Court Overturns Quill

6/26/2018
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Jad Chamseddine talks to David Stewart about the U.S. Supreme Court's decision to overturn Quill in South Dakota v. Wayfair Inc. and the implications of that ruling for state tax collection on remote sales.

Duration:00:10:16