Talking Tax

Brazilian taxpayers and practitioners continue to clamor for more guidance on the country's new transfer pricing regime implemented last year. The country switched from a mathematical model to an arm's-length principle for transfer pricing last year, bringing it in line with global standards. That pivot left a lot of questions for the Receita Federal, the country’s revenue authority, to answer through guidance, and it's been working to issue rules ever since. Most recently, Brazil issued instructions requiring extensive reporting and documentation of transactions involving commodities and how companies calculate their transfer pricing positions. Transfer pricing involves valuation of transactions between entities within a corporate group. Intragroup transactions must be conducted at arm’s length—priced similarly to transactions between unrelated companies. The country’s auditors are gearing up to enforce Brazil's new rules, sparking some concerns among practitioners that many new auditors will be learning on

Treasury Department and IRS finalized rules requiring crypto exchanges to provide information on taxpayers’ buying and selling activities are meeting industry and Republican pushback. Centralized brokers must issue form 1099-DA, starting in 2026 for tax year 2025, and decentralized brokers are to start doing so in 2028 for tax year 2027. The form includes such things as personal data, gross proceeds on sales, and transaction dates. Crypto tax advisers bring up two themes about the new rules: First, it's challenging for some brokers to implement the infrastructure needed to comply with the reporting requirements because tracking transactions is a huge undertaking when trades happen so quickly. Second, some Congressional Republicans don't like the rule and have introduced a joint resolution to nullify parts of the regulations. In this episode of Talking Tax, Bloomberg Tax reporter Rebecca Chen chats with Jessalyn Dean, vice president of tax information reporting at digital asset tax and accounting platform Led

President Donald Trump threw a major wrench into the fate of the OECD global tax deal on his first day in office, sparking concerns among the international tax community about the deal being fundamentally reshaped. Trump issued a presidential memo Jan. 20 stating the global tax deal has no "force or effect" in the US and instructed the Treasury Department to come up with a list of protective measures to impose on any country that enacts discriminatory or extraterritorial taxes against American taxpayers. This week, Bloomberg Tax reporter Lauren Vella sits down with Scott Levine, Treasury's former deputy assistant secretary for international affairs and top US OECD tax delegate, to chat about the status of the global deal and the impact of the new US administration's position on negotiations. Levine maps out two scenarios he sees playing out in Paris under the new Trump administration and gives some insight into how countries at the OECD might be feeling about the transition of power in the US. Do you have fee

Few of the provisions of the tax code this year have garnered as much attention from industry as the about-to-sunset pass-through deduction. In their 2017 tax overhaul, Republicans allowed owners of pass-through businesses such as partnerships, S-corporations, and LLCs to deduct 20% of certain business income from their taxes. Businesses and their lobbyists say it gives those firms small and large parity with traditional corporations. Critics say its benefits largely flow to the wealthy. That deduction—along with the rest of the individual provisions of that 2017 law known as the Tax Cuts and Jobs Act—expires at the end of 2025 absent congressional action and President Donald Trump's signature. On this episode of Talking Tax, Bloomberg Tax reporter Zach Cohen spoke with two guests about what the deduction does and prospects for renewal by Congress this year. Jeff Brabant is a vice president of federal government relations at the National Federation of Independent Businesss, and Elena Spatoulas Patel is a nonr

The leader of a top US standard-setter wants his board to take the next step in using emerging technology to craft accounting rules for local and state governments. Joel Black, chair of the Governmental Accounting Standards Board, said a key priority for the board this year is shifting gears from monitoring emerging tools such as artificial intelligence to preparing for its future integration. In his final two years as leader, Black said he intends to craft an enduring focus on how technology can make financial reporting more efficient. GASB establishes standards for state and local governments that follow generally accepted accounting principles, or GAAP. Cities and states' staffing shortages and resource constraints have motivated the board to be especially selective about the projects it takes on, Black said. The board is currently working to update how governments should value infrastructure assets such as bridges and tunnels, as well as develop digital classifications for financial reporting. Black, who

President-elect Donald Trump's plans to deconstruct the federal workforce would take a bite out of IRS efforts to answer taxpayer phone calls and enforce compliance for tax cheats. After getting billions in funding from the 2022 tax-and-climate law, the IRS started a long-needed rebuild, including bringing on more workers. Between Oct. 1, 2021 and Sept. 30, 2023, the IRS processed nearly 53,000 new hires, the Treasury Inspector General for Tax Administration said in a September report. But Trump's promises to end remote work for federal workers and reinstate a policy that would make it easier to fire certain employees are seen as ways to end the IRS's competitiveness in the job market and ability to keep employees who are flight risks. Bloomberg Tax reporter Erin Slowey spoke with Kelly Reyes, executive director of the Professional Managers Association that represents the interests of IRS managers, about what a presidential transition means for IRS employees and how agency managers are preparing for next tax

Jan. 3 marks the beginning of the next Congress, where Republicans will lead both chambers and control the White House. Democrats being out of power has big implications for tax policy, as GOP lawmakers heading into the new year debate what to renew from the 2017 GOP tax law, known as the Tax Cuts and Jobs Act. The TCJA was passed with no votes from Democrats and benefits skewed toward the wealthy and corporations. Incoming GOP leaders have proposed breaking their top priorities into two bills and moving them through Congress using the reconciliation process. The first would jump-start President-elect Donald Trump's priorities on immigration and gas drilling, and the second would include tax and other legislative priorities. Republicans say moving tax legislation to later in the year would give them more time to decide what to do about many of the law’s individual provisions that expire at the end of 2025. They also will have to decide what Trump campaign promises to include. On this episode of Talking Tax, B

Online retailers that rely solely on third-party logistics providers like Amazon for tax compliance may still face tax liability for direct sales through their own websites. Many states enacted marketplace facilitator laws in the years since the Supreme Court's 2018 ruling in South Dakota v. Wayfair, shifting tax collection responsibilities to platforms like Amazon or Walmart. But individual vendors can still face additional tax obligations because of direct sales, how their inventory is controlled, or state-specific sales thresholds. As of October, most of the 24 states in the Streamlined Sales and Use Tax Agreement, which aims to simplify sales tax codes, said inventory in a third-party warehouse creates a physical nexus—a connection that triggers tax responsibilities. Rules vary even more outside the Streamlined pact. In New York, for instance, storage alone is sufficient for nexus, while in Arizona, inventory beyond a seller’s control likely doesn't. Bloomberg Tax reporter Angélica Serrano-Román and Diane

A new White House administration and Republican-led Congress are slated to disrupt how the IRS operates. Republicans' taste for cuts to the agency's annual appropriations and the tens of billions of added funding from the 2022 tax-and-climate law is putting the IRS and the Treasury Department on offense, as they make a case for why a well-funded IRS is good for everyone. The Treasury Department has warned that further clawbacks would mean customer service—a bipartisan concern—as well as enforcement efforts, would take a hit. Bloomberg Tax's Erin Slowey spoke with Charles Rettig, a shareholder at Chamberlain Hrdlicka, on why the IRS needs its funding and how a new commissioner could shake up the agency. Rettig, who served as commissioner during the first Trump administration, also addressed what he is telling his clients amid the uncertainty. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Fuel producers are trying to prepare for a tax credit regime change, even though the Treasury Department has failed to issue rules around those credits. The clean fuel production tax credit under Section 45Z takes effect next year, replacing a longstanding blenders credit. The new credit gives tax breaks to fuel according to its carbon intensity score. But the yet-to-be-released Treasury and IRS rules will explain how to calculate that score. Debbie Gordon, leader of RSM US LLP's excise and energy tax practice, told reporter Erin Schilling on this week's episode of Talking Tax podcast that fuel producers are still trying to prepare for the new credit, even amid that uncertainty. It's unclear when the clean fuel production tax credit rules will come out, though a Treasury spokesperson said the Biden administration expects to put out some guidance before the administration change in January. Many also are trying to push to start construction on clean fuel projects before the end of this year to qualify for the

US companies are ramping up their efforts to lobby Congress on the international tax provisions they'd like to see in a comprehensive 2025 tax bill.   Among their priorities is retaining the current rates on foreign income, which were included in Republicans' 2017 tax law and are poised to increase in 2026. But there are open questions about how lawmakers can pay for these extensions and make good on President-elect Donald Trump's domestic corporate tax proposals. On this week's episode of "Talking Tax," reporter Lauren Vella sits down with Rohit Kumar, co-leader of PwC's National Tax Office, to discuss which international tax provisions could be addressed in a 2025 bill. He also offers insight into how companies are thinking about the 15% global minimum tax with Republicans taking full control of the White House and Congress. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690

The re-election of Donald Trump and Republican sweep in Congress makes an extension of the 2017 GOP tax cuts more likely, but there will be hurdles. Republicans want to use a fast-track process to move legislation—but that maneuvering comes with various rules and procedures. Meanwhile, senators in the party elected John Thune (R-S.D.), a long-time member of the Finance Committee, to become majority leader in January, succeeding Sen. Mitch McConnell (R-Ky.) Thune's experience on the Finance panel when the law known as the Tax Cuts and Jobs Act was crafted could help smooth the process. On this episode of Talking Tax, Bloomberg Tax Deputy Team Leader Kim Dixon and reporter Zach C. Cohen discuss the new GOP Senate leader and how the fast-track process known as reconciliation could play out when Republicans take power in Washington next year. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690

The IRS is winning more cases in the US Tax Court over companies' valuation of intangible assets, such as patents and trademarks, through transfer pricing. The wins have caught the attention of companies and practitioners as they mull the growing risks of transfer pricing, which governs transactions between related companies that are part of the same multinational group. Disputes between the IRS and companies such as Coca-Cola and 3M have showcased the agency's newfound ability to audit their positions and win in Tax Court when challenged. Both cases are being appealed. In addition, a new IRS policy to assess more penalties when documentation is lacking could make companies' transfer pricing positions much riskier than in the past, practitioners say, and taxpayers may have to start factoring that in. In this week’s Talking Tax podcast, Bloomberg Tax reporter Caleb Harshberger spoke with Grant Thornton LLP Transfer Pricing Technical Leader Steve Wrappe and Greenberg Traurig LLP shareholder Sharon Katz-Pearlman

The nation is unpacking what comes next with Donald Trump's second presidency and with a Senate that flipped from Democratic to Republican. One of the biggest questions that remains unanswered is how this impacts upcoming talks over myriad provisions in the GOP's signature 2017 tax law that expire at the end of 2025. Idaho Republican Sen. Mike Crapo—no stranger to tax policy and negotiations—becomes chair of the Senate Finance Committee and will have a major hand in what happens with those expiring provisions that were part of the legislation known as the Tax Cuts and Jobs Act. Crapo is seen as a behind-the-scenes operator but his new role puts him at the center of talks to decide what to keep and what to jettison from a tax package that could have a price tag in the trillions of dollars. A second Trump presidency also has implications for the IRS. Republicans have threatened to claw back supplemental IRS modernization funding, and have criticized the agency's focus on the Direct File program, offering free f

California regulators are prepared to walk away from strict licensing rules that require accountants to earn the equivalent of five years of college to qualify. The California Board of Accountancy has proposed reforms that would grant the certified public accountant license to candidates with a traditional bachelor’s degree plus two years of work experience in addition to passing the CPA exam. The proposal would unwind current rules that call for 150 hours of college credits to qualify—a requirement that is seen as a barrier to entering the profession. Instead, the board's draft legislation would strip the specific number of college credits from its rulebook to focus on the degree earned or the candidate’s coursework. State lawmakers would have to approve any changes. Bloomberg Tax senior reporter Amanda Iacone spoke with Dominic Franzella, the executive officer of the state accountancy board, about how California's proposal matches up against related reforms the American Institute of CPAs introduced in Septe

Artificial intelligence is becoming a bigger part of tax practice and policy every day. The Big Four are spending billions of dollars on AI models, and even mid-tier accounting firms seem willing to at least tread into generative AI transformation, albeit slowly. These investments raise questions about how corporate in-house tax departments are evaluating AI integration. In this special edition of Talking Tax, Bloomberg Tax Insights editor-at-large Rebecca Baker chatted with three different in-house tax leaders to hear their views on the emergence of AI in the profession, and in their lives. While they all agree AI must be part of the conversation now, they have different takes on how it should be used—or if it should even be used at all. Kurt Lamp, vice president of global tax at Amazon, is the most bullish on pulling AI tools into the corporate tax function, noting the ability to extract data and automate tasks. Jessica Reif-Caplan, legal principal in tax and business development at Edward Jones, takes a lo

The fate of the 2017 GOP tax overhaul is top of mind for corporations in the weeks leading up to the election. Many of the law's provisions are expiring in 2025, setting Congress up to negotiate another major tax law. Corporations are closely watching what happens to bonus depreciation, interest expense deductions, and research and development expensing, S&P Global Rating Managing Director Shripad Joshi said. Plus, both presidential candidates have campaigned on changing the corporate tax, which the 2017 law permanently lowered to 21%. Without knowing who will control the White House and Congress next year, it's difficult for corporations to plan ahead. Right now, they're reviewing tax proposals that may be considered and modeling how different scenarios could impact them. That means figuring out where their tax weaknesses lie and parsing out which changes could hurt or help cash flow the most. On this episode of Talking Tax, Bloomberg Tax reporter Erin Schilling talks with Joshi about how corporations are de

After more than two years, the Treasury Department has proposed rules to implement the new minimum tax on companies’ book income. Now comes the hard part. The regulations, which Treasury issued last month, would govern how the corporate alternative minimum tax is applied and calculated. CAMT, enacted in 2022, requires big companies to pay at least 15% in taxes on the income they report on their financial statements—a crackdown on companies that have been able to pay little or nothing in the past by taking advantage of tax breaks and tax-planning strategies. The proposed regulations run to more than 600 pages, and set up a highly complex regime for companies that fall under CAMT. Tax professionals and companies continue to pore over the rules, to see what kind of effects they’ll have. Bloomberg Tax senior reporter Michael Rapoport spoke with Monisha Santamaria, a principal in KPMG LLP’s Washington National Tax practice about the complexity of the CAMT regulations; some notable aspects of the rules; how CAMT wi

The European Court of Justice's ruling against Apple Inc. over a $14.4 billion Irish tax bill stunned members of the international tax community, who said it throws the high court's precedent on tax state aid cases into disarray. The EU high court ruled last month that the company's tax positions in Ireland, which were agreed to by Irish authorities in 1991 and 2007, amounted to illegal state aid. EU law stipulates that member states shouldn't give companies preferential treatment—state aid—over other businesses. Unlawful state aid could come in the form of preferential tax benefits. The decision was particularly perplexing to tax observers because it didn't rely on rulings in similar, previous high-profile cases involving Fiat Chrysler or Amazon, where the ECJ sided with the companies rather than the European Commission. This week, Bloomberg Tax reporter Lauren Vella chats with University of Virginia professor Ruth Mason and Stephen Daly, reader in tax law at King’s College in London, who say that there is a

The Multistate Tax Commission dates to the 1960s, yet the intergovernmental tax agency and its mission on behalf of state revenue departments are often not well understood. The map of tax laws and regulations across the 50 states would be much more complicated and inconsistent without the efforts of committed attorneys, auditors, and administrators working on behalf of the commission. On this episode of Talking Tax, Bloomberg Tax senior reporter Michael J. Bologna discusses the MTC's goals and achievements with former general counsel Nancy Prosser, who retired Sept. 24. Prosser talks about the agency’s essential mission to promote uniform and consistent tax policies across the states, and assist taxpayers in achieving full compliance. She also stresses the MTC’s efforts to advocate for state and local sovereignty in the development of tax policy. Prosser retired after four years as general counsel and a 16-year career in tax administration with the Texas Comptroller for Public Accounts, including two years as