Talking Tax is on hiatus for a bit while we create some great new episodes for you. Until then, we're pleased to offer a special presentation of our ABA Silver Gavel award-winning series, UnCommon Law. Generative AI tools are already promising to change the world. Systems like OpenAI's ChatGPT can answer complex questions, write poems and code, and even mimic famous authors with uncanny accuracy. But in using copyrighted materials to train these powerful AI products, are AI companies...

The new 15% global minimum tax that took effect this year is turning out to be compliance beast. The tax, which is part of an international tax deal agreed to by more than 140 countries in 2021, contains a slew of new technical terms, complex rules, and hundreds of pages of administrative guidance. Now, some of the largest accounting firms in the world have been tasked with interpreting these rules, educating their clients, and building complex data systems to help multinational companies...

A looming decision from the US Supreme Court on federal agency rulemaking power is fueling chatter on just how much it could upend the regulatory process at these agencies. Justices in January heard two cases, Relentless v. Dept. of Commerce and Loper Bright Enterprises v. Raimondo, which challenge the decades-old landmark administrative principle known as the Chevron doctrine saying that federal courts should defer to agency interpretation when a law is vague. Bloomberg Tax reporter Erin...

A seven-year-old lawsuit aimed at forcing overhaul of New York City's complicated property tax system has gotten a new life, after the state's high court ruled last month it could move forward. Tax Equity Now New York, a broad housing coalition, sued the city and the state in 2017, arguing that the city's method for collecting property taxes favors wealthy, white homeowners at the expense of owners and tenants in lower-income neighborhoods. But the suit was dealt a blow in 2020, when a...

While senators quibble over the $78 billion bipartisan tax package, the House is turning to next year, when a swath of tax cuts from the Republicans' 2017 law expire. Congress returns next week, and it's unclear if the full Senate will vote on the tax bill, which is stalled over GOP objections despite getting an overwhelmingly bipartisan House vote in January. The fate of the package of tax breaks for families and businesses likely has ramifications for 2025 tax talks, as Senate Finance...

The corporate jet industry is the latest to be targeted by the government's efforts to make the rich pay the taxes they owe. The IRS began an audit campaign in February to clamp down on executives abusing corporate jet tax breaks for personal use. President Joe Biden's proposed budget would tighten depreciation rules and increase the tax rate on private jet fuel, and Senate Democrats sent a letter urging the Treasury Department and Internal Revenue Service to change how corporate jet owners...

Coming soon to corporate financial statements: a lot more tax transparency. After seven years and three rounds of proposals, the Financial Accounting Standards Board in December published new rules requiring companies to shed light on the income taxes they pay to federal, international, and state governments. The disclosure rules, which kick in as early as 2025, are a response to years of complaints that current financial reporting rules offer too few details about tax obligations. Soon,...

Many taxpayers with relatively simple returns can now electronically file their returns directly with the IRS for free for the first time. The IRS, after months of preparing its government-run free e-filing pilot tool, launched the program to the wider public Tuesday. The Treasury Department expects about 100,000 of the millions eligible to use it. Democrats’ Inflation Reduction Act set aside $15 million for the IRS to issue a report on the feasibility of creating a direct e-filing tax return...

Australian authorities continue to crack down on multinational companies it believes are trying to avoid Australian taxes—and a recent court ruling against PepsiCo Inc. gives them a tough weapon. A judge ruled in November that sales of beverage concentrate from a Singapore Pepsi affiliate to an Australian Pepsi bottler also effectively included royalties for the use of Pepsi trademarks and intellectual property that the company should have been taxed on. But for the first time, the judge also...

Sports team owners for decades have seen enormous tax benefits from their team purchases, dispatching squads of accountants to find write-offs on things from equipment and player salaries to TV rights and more. Now the IRS is looking to make sure all of those savings were above board. The IRS's Large Business and International Division announced the audit campaign last month, making sure the income and deductions taken by sports-related partnerships with large losses are reported in...

For more than a decade, states have had to grapple with the challenge of taxing the digital economy. Peering into cyberspace, tax administrators were often left with more questions than answers. What online products and services should be taxed? How does a state source a virtual creation to a specific jurisdiction? Can states even tax digital products and services in the face of federal limits on discriminatory taxes on electronic commerce? State tax authorities now have to answer these...

State film tax credit programs are increasingly financing advertisements for some of the world’s largest consumer product companies, some of which subsequently sell the credits to other companies looking to reduce their state tax liabilities. Twenty-eight states and Puerto Rico allow such incentives for production of commercials. Major companies, including McDonald’s Corp., Kellanova, and AbbVie Inc., receive these to promote products such as burgers, cereal, and prescription drugs. Tax...

More than 146 million individual tax returns are expected to be filed before the end of the 2024 tax filing season. The IRS, with the help of the tens of billions of dollars in supplemental cash from the Democrats' 2022 tax-and-climate law, built up its call centers, expanded its online options, and is now offering more hours at its taxpayer assistance centers to help make a smoother tax filing season for taxpayers and tax professionals. It also launched a controversial free agency-run filing...

For decades, states’ authorities to tax the earnings of multinational corporations have ended abruptly at the “water’s edge.” Frustration with this limitation, however, has grown in recent years as large, sophisticated businesses employ accounting techniques and asset transactions to shift their domestic earnings offshore. Mandatory worldwide combined reporting—an apportionment method requiring the calculation of taxes based on global income attributable to a particular jurisdiction—is one...

Michael Plowgian, who in December left his role as deputy assistant secretary for international affairs at the Treasury Department, had an eventful stint at the department. The former top OECD negotiator for the US started at Treasury in October 2021 as a counselor right around the time over 140 countries agreed to the global tax deal. Since then, Plowgian has been a part of large steps in the deal's progression—from tranches of Pillar Two rules to the release of a draft multilateral treaty...

Leaders of the House and Senate tax-writing committees unveiled a bipartisan framework this week that pairs business breaks with an expansion of the child tax credit, but a path toward passage remains rocky. Despite having the blessing of Senate Finance Chair Ron Wyden (D-Ore.) and Ways and Means Chair Jason Smith (R-Mo.), the panels' ranking members aren't yet sold. And while the framework has support from Senate Majority Leader Charles Schumer (D-N.Y.), it's not certain whether Speaker Mike...

In a Congress where lawmakers are divided on an overwhelming set of issues, helping to alleviate double taxation for businesses operating in both the US and Taiwan is one with rare bipartisan unity. House Ways and Means Committee members voted in unison to send a bill to the House floor aimed at providing treaty-like benefits to the island democracy. Leaders of both the House and Senate tax-writing committees gave the bill their bipartisan blessing and say they're pushing for speedy...

Over the past six months, the OECD has released multiple documents with more details on parts of the international tax deal agreed to by over 140 countries in 2021. But even with the additional clarity from the Organization for Economic Cooperation and Development, there are still fundamental questions about key parts of the deal—such as a simplified transfer pricing method, known as Amount B—that remain. The tax agreement comprises two parts: a reallocation of large multinationals' residual...

The union that represents about 65,000 IRS employees is teaming up with the agency to help attract new talent amid a hiring spree. The Democrats' tax-and-climate law gave the IRS tens of billions to dollars to modernize and go after taxpayers who haven't been paying what they owe. To do that, the IRS needs to build up its workforce, but it is competing with the more-lucrative private sector. That's where the National Treasury Employees Union is stepping in. Bloomberg Tax reporter Erin Slowey...

More of the supply chain that helps create semiconductor chips wants in on a lucrative new tax credit aimed at boosting US competitiveness against China. As of now under IRS proposed rules, companies that manufacture materials or chemicals supplied to the manufacturing of semiconductors or equipment don't qualify for the 25% tax credit from the 2022 CHIPS Act. Bloomberg Tax’s Erin Slowey speaks with Tymon Daniels, vice president of tax for Corning Inc., a US materials science company that is...

African countries face several challenges in negotiating the global tax deal involving more than 140 countries at the Organization for Economic Cooperation and Development. The agreement includes reallocation of the residual profits of large multinational companies to market jurisdictions, known as Pillar One, and a 15% global minimum tax, known as Pillar Two. On this week’s episode of Talking Tax, Bloomberg Tax senior reporter Danish Mehboob speaks with Logan Wort, executive secretary at the...

Marita Sciarrotta, the new acting director of New Jersey's Division of Taxation, will have a busy year ahead as she settles into the role. Sciarrotta, who spent 40 years in the tax division before taking over as acting director in September, said in an interview that she wants to modernize the state's property tax relief programs—an endeavor that likely will require legislation to make needed changes. She also plans to increase hiring as state revenue agencies across the nation grapple with a...

(Note: This episode originally aired June 1, 2023) What does it mean to be a good tax leader, as an in-house tax professional or as a tax adviser who wants to make the tax functions of your clients better? How do you build a great team? Bloomberg Tax Insights editor Rebecca Baker sat down with Jared Dunkin, the vice president of tax and senior tax counsel at FTI Consulting, and Dunkin’s mentor and former boss, Todd Davis, the executive vice president and senior tax counsel for Warner Bros....

For more than a year, a group of wealth management advisers met regularly to devise strategies to defend their wealthy clients' keeping their riches in individual retirement arrangements based in Malta. The pension plans—which emerged out of a loophole in a 2011 tax treaty between the US and the Mediterranean island nation widely seen as a tax haven—involved a cottage industry of advisers, accountants, and attorneys to facilitate transactions that allowed cash, business interests, and several...