Send us a text

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. 

Listen to our previous episodes on the two pillars here:

• An Update on Pillar 1 Amount B
• Pillar 1 Amount B: Disagreements and Divides
• Manal Corwin Takes the Helm: Updates on the OECD Tax Reform Plan
• Bringing Order to Chaos? Digital Services Taxes and Pillar 1

For more coverage, read the following in Tax Notes:

• IRS to Propose Regs on OECD Amount B Transfer Pricing Approach
• IRS Wants to Preserve DCL Regime Election Amid Pillar 2 Rules
• OECD Transitional Pillar 2 Tax Peer Review Nearing Completion
• UAE to Introduce OECD-Aligned Domestic Minimum Top-Up Tax
• Australian Senate Approves Package of Global Minimum Tax Bills

Follow us on X:

• Stephanie Soong: @StephanieSoong
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes

Send us a text

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.

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:

• Tax Department Leadership: Effective Succession Strategies 
• Best Practices for Recruiting Critical Tax Roles
• Optimizing Tax Talent in Challenging Times
• Evaluating Critical Remote Arrangements in Corporate Tax Departments

Follow us on X:

• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

Send us a text

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.

For more, check out the team's coverage on private placement life insurance:

• Chance of Changes to Life Insurance ‘Wrappers’ Dims Postelection
• How Offshore Life Insurance Helps Business Owners Minimize Taxes
• High-End Life Insurance Policies Lured Offshore by Relaxed Rules
• Inside How Private Placement Life Insurance Slips Through the Cracks

To hear Senator Wyden's full statement, visit https://www.youtube.com/watch?v=xiez_NnUBZQ.

Follow us on X:

• Lauren Loricchio: @LaurenLoricchio
• Chandra Wallace: @ChandraSWallace
• Sarah Paez: @PaezWrites
• Kiarra Strocko: @KiarraStrocko
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

Send us a text

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.

For more coverage, read the following in Tax Notes:

• IRS Is Well Positioned to Handle Tax Bill, Werfel Says
• IRS Council Calls for Public Education About Tax Noncompliance
• IRS to Beef Up Artificial Intelligence Oversight Structure
• Election Results Cast Doubt on Fate of IRS Funding, Direct File
• Werfel Says Agency Is Gearing Up to Weigh In on TCJA Expiration

Follow us on X:

• Ben Valdez: @benmvaldez
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

Send us a text

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. 

For other episodes from Cape Town, listen to:

• "From Cape Town: A Sit-Down With South Africa's Top Tax Official."
• "From Cape Town: Developing Tax Policy for Developing Nations."

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:

• OECD Framework Discussing Permanent Pillar 2 Safe Harbors
• Frustration Persists in OECD Framework Over Pillar 1
• Lithuania Tax Authority Proposes Pillar 2 Implementing Rules
• Latvian Parliament Passes Global Minimum Tax Legislation

Follow us on X:

• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

Send us a text

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.

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:

• Trump Win Casts Shadow Over OECD Global Tax Reforms
• OECD Framework Discussing Permanent Pillar 2 Safe Harbors
• Frustration Persists in OECD Framework Over Pillar 1
• U.N. Official Floats Cooperation With OECD on Tax Dispute Issues
• New U.N. Model Tax Treaty Article Is a Win for Developing Countries
• Bilateral Treaty Sourcing Rules Harm Developing Countries, Paper Says

For information about our live Taxing Issues event, visit: https://events.taxanalysts.org/tawebinar112024 

Follow us on X:

• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

Send us a text

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.

For more coverage, read the following in Tax Notes:

• DSTs Could Violate Tax Treaty Obligations, U.N. Official Says
• EU Commission Fully Supports Permanent Pillar 2 Safe Harbor
• OECD Framework Discussing Permanent Pillar 2 Safe Harbors
• Frustration Persists in OECD Framework Over Pillar 1
• U.N. Official Floats Cooperation With OECD on Tax Dispute Issues
• New U.N. Model Tax Treaty Article Is a Win for Developing Countries
• South African Tax Chief Warns Taxing Right Fight Will Intensify

For information about our live Taxing Issues event, visit: https://events.taxanalysts.org/tawebinar112024 

Follow us on X:

• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

Send us a text

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.

Listen to our previous episodes on taxing hidden assets:

• The Constitutionality of Penalties on Undeclared Assets
• America the Tax Haven? Exploring the U.S. Trade Deficit

For more coverage, read the following in Tax Notes:

• Trump Vows to End ‘Double Taxation’ of Overseas Citizens
• Court Tells DOJ No Do-Over in Venture Capitalist FBAR Case
• EU, Belgium Say Domestic Bank Secrecy Hinders Tax Transparency
• U.S., Switzerland to Exchange Info Under New FATCA Deal From 2027
• IRS Approves Argentina’s Data Security for FATCA Exchanges
• Transparency Not a Threat to Privacy, Tax Justice Network Says

For information about our live Taxing Issues event, visit: https://events.taxanalysts.org/tawebinar112024 

Follow us on X:

• Bob Goulder: @RobertGoulder
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

Send us a text

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 Tax

For more coverage, read the following in Tax Notes:

• Exempt Orgs Get Temporary Break From Filing Corporate AMT Form
• Corrections Coming for Corporate AMT Proposed Regs
• Treasury Downplays FTC Timing Concerns in Corporate AMT Regs
• More Corporate AMT Safe Harbors Are on the Table
• Analysis: CAMTyland Adventures, Part V: Coping With CAMTyland Grief

For information about our live Taxing Issues event, visit: https://events.taxanalysts.org/tawebinar112024 

Follow us on X:

• Chandra Wallace: @ChandraSWallace
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

Send us a text

Tax Notes White House reporter Alexander Rifaat discusses the tax policies proposed by Vice President Kamala Harris and former President Trump.

For more coverage, read the following in Tax Notes:

• Trump Proposes Tax Write-Off for Generator Purchases
• Trump Proffers Tax Incentives for Car Owners, Manufacturers
• Trump’s Plan Would Swell Deficit More Than Harris’s, Study Says
• No Indication Vance Will Release Tax Returns
• Harris Proposes New Manufacturing Tax Credit
• Unrealized Capital Gains Proposal Faces Uncertain Path
• Harris Says ‘Trump Tax’ Would Cost Americans $4,000 Annually
• Harris Held Talks With Union Before Making Tip Pledge

Audio clips obtained from C-SPAN.

Follow us on X:

• Alexander Rifaat: @AlexRifaat
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart

Send us a text

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 Willful
• FBAR Penalty Circuit Split Has Potential for Supreme Court Review
• Schwarzbaum FBAR Penalty Dispute Results in Circuit Split
• Court Tells DOJ No Do-Over in Venture Capitalist FBAR Case
• Ninth Circuit Approves Prejudgment Interest for FBAR Penalties

Follow us on X:

• Bob Goulder: @RobertGoulder
• David Stewart: @TaxStew
• Tax Notes: @TaxNotes

***
Credits
Host: David D. Stewart
Executive Producers: Jasper B. Smith, Paige Jones
Showrunner: Jordan Parrish
Audio Engineers: Jordan Parrish, Peyton Rhodes
Guest Relations: Alexis Hart