Tax Notes Talk

Professor Sakinah Tillman of the University of the District of Columbia David A. Clarke School of Law discusses how the complexities of state tax debt collections disadvantage low-income taxpayers. For more, read Tillman's article, "Impact of Vague State Tax Collection Alternatives on Low-Income Taxpayers." ** Credits Host: David D. Stewart Executive Producers: Jeanne Rauch-Zender, Paige Jones Producer: Jordan Parrish Audio Editor: Laura Kondourajian **** This episode is sponsored by Portugal Pathways. For more information, visit portugalpathways.io. This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Professor Lauren Shores Pelikan of the University of Missouri School of Law discusses her proposal to create a tax benefit for individual childcare service providers to ease costs for working parents. For more on Shores Pelikan's proposal, read "Toddlers, Investors, and Tax Policy." For more on the LendingTree study, read "It Costs an Additional $303,418 to Raise a Child Over 18 Years, Up 1.9%." ** Credits Host: David D. Stewart Executive Producers: Jeanne Rauch-Zender, Paige Jones Producer: Jordan Parrish Audio Editor: Laura Kondourajian **** This episode is sponsored by Portugal Pathways. For more information, visit portugalpathways.io. This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Former IRS Criminal Investigation division Chief Guy Ficco examines the agency's future, including immigration enforcement and the use of artificial intelligence, as his decades-long tenure ends. For more on the IRS Criminal Investigation division, read the following in Tax Notes: IRS Criminal Investigators Pull Back From Immigration, PolicingFirmness of IRS Voluntary Disclosure Policy Worries Tax LawyersJ5 Warns of Use of Crypto Platforms for Tax Evasion, Other CrimesIRS Shakes Up Leadership With Filing Season Looming** Credits Host: David D. Stewart Executive Producers: Jeanne Rauch-Zender, Paige Jones Producer: Jordan Parrish Audio Editor: Laura Kondourajian **** This episode is sponsored by Portugal Pathways. For more information, visit portugalpathways.io. This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Benjamin Angel, director of direct taxation at the European Commission’s Directorate-General for Taxation and Customs Union, discusses the EU’s biggest tax challenges right now, including windfall taxes and the side-by-side package. For more, read the following in Tax Notes: EU Draft Floats Binding Measures to Reduce Electricity TaxesTax Cuts Don’t Pay for Themselves, EU Commission SaysSimplify Pillar 2-Linked Rules, Avoid DSTs, Stakeholders Tell EU** Credits Host: David D. Stewart Executive Producers: Jeanne Rauch-Zender, Paige Jones Producer: Jordan Parrish Audio Editor: Laura Kondourajian **** This episode is sponsored by Portugal Pathways. For more information, visit portugalpathways.io. This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Jennifer Bernardini of PwC discusses the recently released guidance for the material assistance and prohibited foreign entity rules affecting some of the clean energy credits in the One Big Beautiful Bill Act. For more, read the following in Tax Notes: Dems Lay Groundwork to Restore Clean Energy Credits Post-MidtermsGOP Bill Would Pause Clean Energy Credit to Pay for Crude OilANALYSIS: Lessons From the Energy Tax Credit Market in 2025** Credits Host: David D. Stewart Executive Producers: Jeanne Rauch-Zender, Paige Jones Producer: Jordan Parrish Audio Editor: Laura Kondourajian **** This episode is sponsored by Portugal Pathways. For more information, visit portugalpathways.io. This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Tax Notes senior reporter Cady Stanton investigated a provision of the low-income housing tax credit and talked to housing advocates and tenants about how a 1990s tax policy has affected affordable housing. Stanton interviewed the following people for this episode: For more, read Stanton's investigation for free in Tax Notes: Absent Congress, Protecting LIHTC-Funded Housing Has Fallen to StatesCongress Gave Developers Flexibility. It’s Costing People Their Homes.** Credits Host: David D. Stewart Executive Producers: Jeanne Rauch-Zender, Paige Jones Producer and Editor: Jordan Parrish **** This episode is sponsored by Portugal Pathways. For more information, visit portugalpathways.io. This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Erika Isabella Scuderi, visiting assistant professor of tax law at the University of Florida’s Levin College of Law, discusses her proposal for establishing taxing rights in outer space. For more, read Scuderi's article, "On Sovereignty, Outer Space, and Taxation." ** Credits Host: David D. Stewart Executive Producers: Jeanne Rauch-Zender, Paige Jones Producer: Jordan Parrish Audio Editor: Laura Kondourajian **** This episode is sponsored by Portugal Pathways. For more information, visit portugalpathways.io. This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Tax Notes contributing editor Robert Goulder discusses the Supreme Court's ruling invalidating the tariffs set in place by President Trump and what to expect for refunds. Subscribe to History Is Taxing today for free: taxnotes.co/historypodcast For related tax news, read the following in Tax Notes: New Trump Tariffs Hit With Multistate Legal ChallengeANALYSIS: The Real Liberation Day: IEEPA Tariffs Go Down in Flames*** Credits Host: David D. Stewart Executive Producers: Jeanne Rauch-Zender, Paige Jones Producer and Editor: Jordan Parrish **** This episode is sponsored by Portugal Pathways. For more information, visit portugalpathways.io. This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

*** Credits Host: David D. Stewart Executive Producers: Jeanne Rauch-Zender, Paige Jones Producer and Editor: Jordan Parrish Special thanks to Christopher Trigo and Carolyn Kuimelis for their help on this episode. **** This episode is sponsored by Portugal Pathways. For more information, visit portugalpathways.io. This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

U.S. Tax Court Chief Judge Patrick Urda discusses the effects of the IRS’s staff changes and generative AI on the court and its continued evaluation of online access to documents. Listen to our episode with Judge Kerrigan: Updates From the Tax Court: Post-COVID Plans and New Funding *** Credits Host: David D. Stewart Executive Producers: Jeanne Rauch-Zender, Paige Jones Producer and Editor: Jordan Parrish **** This episode is sponsored by Portugal Pathways. For more information, visit portugalpathways.io. This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Tax Notes chief correspondent Stephanie Soong discusses the OECD’s recent pillar 2 side-by-side package deal and how countries are adapting to the new landscape. For related tax news, read the following in Tax Notes: U.S. Focusing on OECD Guidance for Pillar 2 Side-by-Side PackageHungary Expands Global Minimum Tax Registration FormU.S. Treasury Officials Declare Death of OECD Pillar 1 *** 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 the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Rozeta Atlas of HubSync discusses the IRS’s plan to overhaul its legacy IT systems and what a modernized agency may mean for practitioners. For related tax news, read the following in Tax Notes: Palantir Contracts Under Scrutiny Amid IRS Tax Data ControversyIRS Adopts Generative Artificial Intelligence PolicyIRS No-Paper Initiative Jammed by Staffing Issues, Watchdog Says *** 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 the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

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. *** Credits Host: David D. Stewart Executive Producers: Jeanne Rauch-Zender, Paige Jones Producers: Jordan Parrish, Peyton Rhodes Audio Engineers: Jordan Parrish, Peyton Rhodes **** The submissions period for the Tax Notes Student Writing Competition is open! For more information or to submit, visit taxnotes.com/students. This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax. This episode is sponsored by Crux. For more information, visit cruxclimate.com/contact.

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 hearing more about Andrew Kahrl's research on the property tax, check out our episode, "Tax or Theft? Examining the History of the Property Tax." *** Credits Host: David D. Stewart Executive Producers: Jasper B. Smith, Paige Jones Producers: Jordan Parrish, Peyton Rhodes Audio Engineers: Jordan Parrish, Peyton Rhodes **** The submissions period for the Tax Notes Student Writing Competition is open! For more information or to submit, visit taxnotes.com/students. This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax. This episode is sponsored by Crux. For more information, visit cruxclimate.com/contact.

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. *** 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 Crux. For more information, visit cruxclimate.com/contact. This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax. Nominate someone for the Tax Analysts Award of Distinction in U.S. Federal Taxation! For more information, visit awards.taxanalysts.org.

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. *** 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 Crux. For more information, visit cruxclimate.com/contact. This episode is sponsored by Avalara. For more information, visit avalara.com. This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax. Nominate someone for the Tax Analysts Award of Distinction in U.S. Federal Taxation! For more information, visit awards.taxanalysts.org.

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 SaysProposed IRS Funding Cut Draws Concern From Tax WatchersIRS Sets Filing Season Start Date Amid Lofty Refund Expectations *** 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 Crux. For more information, visit cruxclimate.com/contact. This episode is sponsored by Avalara. For more information, visit avalara.com. This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax. Nominate someone for the Tax Analysts Award of Distinction in U.S. Federal Taxation! For more information, visit awards.taxanalysts.org.

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 DeductionsU.S. Chamber Backs Florida Bid to Challenge California Apportionment RuleStates to Face Budget, Tax Policy Questions in 2026 Conformity Debate *** 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 Crux. For more information, visit cruxclimate.com/contact. This episode is sponsored by Avalara. For more information, visit avalara.com. This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax. Nominate someone for the Tax Analysts Award of Distinction in U.S. Federal Taxation! For more information, visit awards.taxanalysts.org.

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 2026New Deficit Projections to Hinge on Giant Tax Bill, TariffsMore Clean Energy Credits Are Set to Expire in 2026 Under OBBBATips and Overtime Reporting Expected to Test Employers in 2026 *** 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 Crux. For more information, visit cruxclimate.com/contact. This episode is sponsored by Avalara. For more information, visit avalara.com. This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax. Nominate someone for the Tax Analysts Award of Distinction in U.S. Federal Taxation! For more information, visit awards.taxanalysts.org.

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 HQMarital Discord Is No Defense to FBAR Penalties, U.S. SaysCrypto Evangelist’s Tax Evasion and Other Convictions Upheld *** Credits Host: David D. Stewart Executive Producers: Jeanne Rauch-Zender, Paige Jones Producers: Jordan Parrish, Peyton Rhodes Audio Engineers: Jordan Parrish, Peyton Rhodes **** Nominate someone for the Tax Analysts Award of Distinction in U.S. Federal Taxation! For more information, visit awards.taxanalysts.org. This episode is sponsored by Avalara. For more information, visit avalara.com. This episode is sponsored by Crux. For more information, visit cruxclimate.com/contact.