Facebook's long-running tax dispute with the IRS finally resumed this month after a lengthy delay caused by the Covid-19 pandemic. The social media giant is fighting IRS allegations that the company undervalued intangible assets that were allocated to its Irish subsidiary. It is one of a string of high-profile cases the IRS is fighting against multinationals over transfer pricing—the value of assets transferred among related corporate entities. The U.S. Tax Court recently heard five days of in-person testimony in Washington and the case is scheduled to shift back to San Francisco early next year. Although the trial focuses only on Facebook's 2010 tax returns, the company has estimated a loss could result in an overall tax liability in the neighborhood of $9 billion, plus interest and penalties. On this episode of our weekly Talking Tax podcast, reporters Jeffery Leon and Aysha Bagchi talk with a pair of tax attorneys who are tracking the Facebook case. Loren Ponds, former majority tax counsel to the House Ways and Means Committee, is now a member with Miller & Chevalier in Washington. Irina Pisareva, a partner with Crowell & Moring LLP in New York, has a quarter-century of experience advising on transaction tax and cross-border tax issues. Our guests dig into the Facebook case, how it differs from a high-profile IRS loss against Amazon.com Inc., and what the court might decide on this long-running legal dispute. Have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Talking Tax

Breaking Down Facebook's $9 Billion Tax Fight With IRS

The Group of 20 finance ministers have formally backed a global plan to overhaul where and how multinationals are taxed and set a minimum 15% corporate tax rate. The OECD-brokered deal—backed by 136 countries— has been years in the making. It now heads into a new phase: Implementation. Officials will next have to tackle a plan to carry out the deal, including rolling back unilateral digital tax measures and drafting model treaties and legislation for countries to use to implement the new rules. On this episode of our weekly Talking Tax podcast, reporter Hamza Ali talks about the latest developments and what's ahead as countries look to implement the historic agreement. Have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Global Tax Pact Gets G-20 Boost, Implementation Awaits

Pandora's box got flung wide open this week, and secrets about how global billionaires and politicians stash their assets came spilling out. The Pandora Papers are a giant leak of millions of financial documents, reported by the International Consortium of Investigative Journalists. They show how many ultra-wealthy people and global leaders are using offshore trusts and other financial entities to store huge amounts of the assets they own. On this episode of our weekly Talking Tax podcast, reporter Michael Rapoport hears two very divergent views on what should be done about this. We hear from Christian Hallum, tax policy lead for the charity and advocacy group Oxfam International, who decries the practices detailed in the documents and says they perpetuate global inequality. And we also speak with Josh Rubenstein, a trusts and estates attorney and national chair of the private wealth department at Katten Muchin Rosenman LLP, who worries that a crackdown could ultimately invade the privacy of law-abiding people who use trusts to manage their wealth. Have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Pandora Papers Offer Peek Into Private World of Rich

In the field of accounting, the robots have most definitely arrived. Front-line accountants may already use some of type of bot, also known as robotics process automation, or RPA. Or maybe they would love to have a bot on their team. Others, of course, may be a bit fearful that automation is going to erase their jobs. To sort out how RPA works, and is evolving, we turned to Loreal Jiles, vice president for research at the Institute of Management Accountants. She previously led an RPA program overseeing both professionals and bots. Bloomberg Tax's Amanda Iacone spoke with Jiles about how RPA can help take tedious and repetitive tasks out of an accountant's day—with no programming experience required. Have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

How Accountants Can Learn to Love the Robots

The House Ways and Means Committee passed a proposal last week to revamp the way U.S. multinationals pay taxes—but to a lesser extent than other Democratic plans on the table. The proposal—part of a broader tax package to help fund Democrats' planned spending of up to $3.5 trillion—would increase the minimum tax on U.S. companies' foreign income and get tougher in other ways on those that do business overseas. It is more modest in some respects than what President Joe Biden and Democrats on the Senate Finance Committee have proposed. On this episode of our weekly Talking Tax podcast, senior reporter Michael Rapoport discusses the House plan with Craig Hillier, the Americas international tax and transaction tax services leader for accounting firm EY. Hillier explains the details of the House proposal and discusses its chances in a narrowly divided Congress. He also talks about how the plan meshes with the pending global tax overhaul agreement among countries at the Organization for Economic Cooperation and Development.

What the House International Tax Plan Would Do

The House Ways and Means Committee approved its portion of a multi-trillion dollar economic and social spending plan this week. But despite this latest victory, Democrats still have a lot of work to do before their aspirations become law. The House tax plan doesn't include some of President Joe Biden's notable proposals, including an overhaul of the way unrealized capital gains are treated at death. The tax plan advanced by Ways and Means also aims for more modest hikes to the corporate and capital gains rates than Biden has been seeking. On this week's episode of our weekly Talking Tax podcast, senior reporter Colin Wilhelm discusses the state of play with two Bracewell LLP lobbyists who have a depth of knowledge on the issues: Yasmin Nelson, former senior policy advisor to then-Sen. Kamala Harris,, and colleague Liam Donovan, a former Republican campaign operative who now works on tax and energy issues as well as providing multi-platform political commentary. Nelson and Donovan break down the opposition to the capital gains overhaul, how a troubled prescription drug pricing proposal impacts the overall revenue picture, and what is happening over on the Senate side of the Capitol. Have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Biden's Capital Gains Overhaul Loses Traction in House

Four years after enactment of the 2017 tax law, the ramifications of Congress' tax code overhaul can be felt thousands of miles away in Ireland, as firms are no longer using the Emerald Isle to shift profits to low-tax jurisdictions. New research by a leading Irish economist shows that many U.S. multinationals are sending outbound payments from Ireland directly to the U.S., rather than to zero- or low-tax jurisdictions. On this episode of our weekly Talking Tax podcast, Seamus Coffey, a lecturer at University College Cork in Ireland talks about how companies are being encouraged to hold intellectual property in places where they have actual economic activity. Have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Irish Tax Schemes a Thing of the Past, Economist Says

Workers across the U.S. are reconsidering their careers at this stage of the pandemic, looking for new job opportunities that offer better pay, benefits, remote work, and other flexibility. The trend, which some have dubbed "The Great Resignation," raises many questions about 401(k) and health savings accounts, jurisdictional taxes, and other tax-related issues. On this episode of our weekly Talking Tax podcast, Bloomberg Tax reporter Jeffery Leon spoke with Eric Bronnenkant, the head of tax at investment advice company Betterment. Bronnenkant talked about why the Great Resignation is happening and the retirement and investment considerations that job seekers should consider when looking at new opportunities. Have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Tax Tips for Job Seekers in ‘The Great Resignation’

College football season starts this weekend and this will be the first year in which the players suiting up can earn significant income off of their name, image, and likeness. Partially in response to losing a case at the Supreme Court, the NCAA this summer lifted its longstanding ban on its student athletes generating this type of revenue for themselves. Though it may not be something most sports fans are thinking about, these newly wealthy athletes, many still in their teens, will run into a host of tax issues if they're not careful. To learn more about this, Bloomberg Tax reporter Sam McQuillan spoke with John Karaffa, the head of ProSport CPA— a firm that specializes in working with athletes—for our weekly Talking Tax podcast. Have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Newly Wealthy Student Athletes to Encounter Tax Issues

The Senate-passed infrastructure bill aims to revive nineties-era taxes on chemical companies and importers to pay for cleaning up some of the nation's most contaminated sites. While the bill still needs to clear the House, the chemicals industry claims the Superfund tax provisions are unfair because they impact a small subset of the industrial sectors that contributed to pollution. But advocates say the return of the "polluters pay" doctrine is a step in the right direction to clean up toxic sites. On this week’s episode of our podcast, Talking Tax, corporate tax reporter David Hood talks to Steve Jawetz, a principal at the environmental law firm Beveridge and Diamond PC who argues the tax is unfairly targeted. David also talks to Danielle Melgar, an advocate with the U.S. Public Interest Research Group’s "Zero Out Toxics” program, about how this tax is a victory for environmental groups. Have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Infrastructure Bill Reignites Superfund Tax Debate

The Senate-passed infrastructure bill includes contentious cryptocurrency tax reporting requirements that the industry is hoping to change when the bill is considered by the House. The requirements would apply to brokers, such as U.S. exchanges, but the industry says the current language is too broad and would hit intermediaries, like software developers and miners, who don't have access to the information they would be required to report. On this week’s episode of our podcast, Talking Tax, senior reporter Allyson Versprille talks to Denise Hintzke, a leader in Deloitte's Global Information Reporting practice. They discuss the impact the reporting requirements would have on the industry and how companies are preparing for the possible changes. Have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Crypto Industry Braces for Tax Reporting Requirements

Investors interested in how companies meet environmental, social, and governance (ESG) standards are also becoming increasingly interested in where—and whether—a company is paying tax. Witold Henisz, a professor at the University of Pennsylvania's Wharton School and founder of the ESG Analytics Lab, argues that tax payments are a critical indicator of a company's broader social impact, and should be factored in to ESG conversations. On this week's episode of our podcast, Talking Tax, Henisz talks to reporter David Hood about how investors are turning to local disclosures to assemble "bespoke data" showing a company's tax burden and payments and why companies will likely face mounting pressure to disclose that type of information. Listen to the episode here. Have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Corporate Taxes Increasingly Seen as Social Obligation

For decades retailers have held onto the sales taxes they collect from consumers for weeks before sending those funds to state revenue agencies. States are becoming increasingly impatient with this process. Some are pushing for accelerated collection schedules and a few are even talking about real-time sales tax compliance strategies. Massachusetts Gov. Charlie Baker (R) has long highlighted accelerated compliance as a way to realize revenue faster and reduce opportunities for tax evasion. On April 1 the Bay State launched an advance payment tax program that shortens the remittance period. Longer term, Baker is recommending a requirement that third-party payment processors convey sales tax to the state on a daily basis, beginning in 2024. On this week's episode of our podcast, Talking Tax, reporter Michael Bologna talks with Liz Armbruester, senior vice president for global compliance at tax software company Avalara, and Patrick Reynolds, senior tax counsel for the Council on State Taxation. Armbruester talks about why she believes that "all signs point to a future where payments will be defined by near-real-time tax compliance," while Reynolds highlights the business community’s concerns about the costs and burdens associated with these compliance strategies. Have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

States Eye Plans for Accelerated Sales Tax Collection

Thalia Smith, a partner at Deloitte, is using her experience as a Black woman in the Big Four to help students looking to break into accounting. Smith, an audit and assurance partner, is leading Deloitte's $75 million effort to close the diversity gap in the accounting profession. Just 2% of the firm's partners, principals, and managing directors are Black. On this week's episode of Talking Tax, Smith talks with reporter Amanda Iacone about her journey to becoming a Deloitte partner and the hurdles she faced as she advanced in an overwhelmingly white profession. Smith earned scholarships that helped her pay for her education and had other support as she prepared for the CPA exam. Deloitte is trying to take out the "luck" element of the process, she said. The firm has committed $30 million to scholarships for hundreds of Black and Latino students. Have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Deloitte Partner Defies Accounting’s Diversity Gap

Tens of millions of families across the U.S. this week received their first monthly advance on the child tax credit from the IRS. The new monthly payments, which launched Thursday, are the result of a pandemic relief law that also temporarily boosted the credit's value. Households will receive up to $300 per month for each child under age 6, and up to $250 for each child ages 6 to 17. While the expanded credit is currently only on the books for this year, Democratic lawmakers are pushing to make sure it stays around long-term. House Ways and Means Committee member Suzan DelBene (D-Wash.) is among the lawmakers who have long championed an expanded tax credit as a way to help reduce child poverty. On this week’s episode of our podcast, Talking Tax, DelBene talks with reporter Kaustuv Basu about why Democrats pushed for the advanced payments and whether a permanent extension is possible. Have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Rep. DelBene on the New Monthly Child Tax Credit

Talking Tax, from Bloomberg Tax, covers tax issues from Capitol Hill and the IRS, to the courts.

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Talking Tax

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