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 Parrish, Peyton Rhodes

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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." 

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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

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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.

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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

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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.

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

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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.

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 Expectations

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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

****
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.

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 Conformity Debate

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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

****
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.

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 in 2026

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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

****
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.

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 Defense to FBAR Penalties, U.S. Says
• Crypto Evangelist’s Tax Evasion and Other Convictions Upheld

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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

****
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.

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 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.

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 Pushes Trump to Revive Tariffs on France Over DST

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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.

***

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.

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 From the 2025 IFA Congress

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

• Bulgarian Parliament Approves Tax Treaty With Malta
• EU’s Tax Priorities Shift as Reform Stalls, Researchers Say
• MNE Profit Shifting Still Persistent, OECD Report Says

***

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.