Christine Green of Steptoe & Johnson PLLC discusses the Corporate Transparency Act and the recent litigation regarding its constitutionality. For additional coverage, read these articles in Tax Notes:U.S. Court Declares Corporate Transparency Act UnconstitutionalYellen: New Beneficial Ownership Reporting Rules Already WorkingFinCEN Finalizes Access Rule for Beneficial Ownership ReportingIRS Criminal Investigators Won’t Enforce New Transparency RulesFinCEN Finalizes Reporting Extension Rule Without More ReliefFollow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Tax Notes contributing editor Ryan Finley discusses the latest developments in three transfer pricing cases — Medtronic, 3M, and Abbott Labs — and their implications for the future. For additional coverage, read these articles in Tax Notes:Business Groups Urge Eighth Circuit to Overturn Tax Court in 3MMedtronic Budges on CUT Method in Round 2 at Eighth CircuitAbbott Labs Revives Fight Over Stock Options in Transfer PricingBlocked Brazilian Income Can’t Be Taxed in U.S., 3M Brief Argues3M Challenges Blocked Income Regs at Eighth CircuitGovernment Resumes Defense of Its Transfer Pricing for MedtronicCoca-Cola’s Brazilian Income Not Blocked, U.S. Tax Court SaysIn our “Editors’ Corner” segment, Edith Brashares, former director in the Treasury Office of Tax Analysis, chats about her coauthored Tax Notes piece, “Is the Economic Analysis Section of Regs Worth the Trouble?” Follow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Professors Edward Fox and Zachary Liscow discuss their proposal for a new tax on billionaires that would apply to borrowing against their assets. For more, read Fox and Liscow's article, "No More Tax-Free Lunch for Billionaires: Closing the Borrowing Loophole," in Tax Notes.For more on wealth taxes, listen to The Wealth Tax Debate.Follow us on Twitter:Robert Goulder: @RobertGoulderDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Tax Notes Capitol Hill reporters Cady Stanton and Doug Sword discuss the key provisions of the Tax Relief for American Families and Workers Act and its potential paths for passage in the Senate. For additional coverage, read these articles in Tax Notes:House Kills SALT Marriage Penalty Bill in Procedural VoteSmith Combats Claims Senate Republicans Weren’t in Tax TalksSenate Border Traffic Jam Pushes Tax Bill Back Weeks, at LeastHouse Tax Deal Vote Hasn’t Swayed Senators Seeking MarkupFollow us on Twitter:Cady Stanton: @cady_stantonDoug Sword: @doug_swordDavid Stewart: @TaxStewTax Notes: @TaxNotes**This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.For more information on Ask Blue J, visit bluej.com/ask. ***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Professor Roberta Mann of the University of Oregon School of Law explains how taxing single-use plastics could help combat their environmental effects.  For more, read Mann's article, "Targeting Plastic Pollution with Taxes."Follow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**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 TaxBandits. For more information, visit taxbandits.com and use promo code TaxNotes5.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Tax Notes managing legal reporter Andrew Velarde discusses the economic substance doctrine dispute in Liberty Global Inc. v. United States and its potential implications. For previous Moore episodes, listen to the following:A Recap of SCOTUS Oral Arguments in Moore v. United StatesMoore Money, More Tax Problems? Analyzing Moore v. United StatesFor additional coverage, read these articles in Tax Notes:ABA Section of Taxation Meeting: Liberty Global Is a Warning Against High-Level Business PurposeLiberty Global Appeals Economic Substance Loss to Tenth CircuitLiberty Global Promises Economic Substance Doctrine AppealEconomic Substance Doctrine Constrains Liberty GlobalFollow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**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 TaxBandits. For more information, visit taxbandits.com and use promo code TaxNotes5.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Kelly Phillips Erb, known online as Taxgirl, discusses the 2024 filing season’s challenges and considerations in light of the IRS’s post-IRA funding changes and the potential for congressional action on a tax deal. For additional coverage, read these articles in Tax Notes:IRS Hasn’t Been Idle During ERC MoratoriumIRS Launches Direct-File PlatformHopes for Senate Markup of Tax Deal Complicated by TimingIRS Unveils Sleeker Notices Ahead of Filing SeasonTax Deal Puts a Damper on Filing Season OptimismWerfel: Shutdown During Filing Season Could Be ‘Very Disruptive’Filing Season Tax Changes Could Be Challenging for Direct FileFollow us on Twitter:Jonathan Curry: @jtcurry005David Stewart: @TaxStewTax Notes: @TaxNotes**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 TaxBandits. For more information, visit taxbandits.com and use promo code TaxNotes5.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Tax Notes contributing editor Robert Goulder discusses the downward attribution dispute in Altria Group Inc. v. United States and the case’s similarities to Moore.Listen to our Moore episodes:A Recap of SCOTUS Oral Arguments in Moore v. United StatesMoore Money, More Tax Problems? Analyzing Moore v. United StatesFor additional coverage, read these articles in Tax Notes:Analysis: The Excise Power: Altria Waits Its TurnAltria’s Case Stayed Pending Realization Decision in MooreAltria Challenges IRS Downward Attribution Control AnalysisFollow us on Twitter:Robert Goulder: @RobertGoulderDavid Stewart: @TaxStewTax Notes: @TaxNotes**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 TaxBandits. For more information, visit taxbandits.com and use promo code TaxNotes5.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Tax Notes contributing editor Nana Ama Sarfo discusses global tax transparency efforts, specifically beneficial ownership registries and country-by-country public reporting. For more, read Sarfo's analysis in Tax Notes: New Year, New Expectations for Global Tax TransparencyFollow us on Twitter:Nana Ama Sarfo: @nanaama_sarfoDavid Stewart: @TaxStewTax Notes: @TaxNotes**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 the Tax Attorney Recruiting Event. For more information, visit the-tare.com.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart

Stephanie Do of the Council On State Taxation discusses key state tax policy topics that are likely to see action in 2024, including the expiration of Tax Cuts and Jobs Act provisions. For additional coverage, read these articles in Tax Notes:West Virginia Governor Highlights Fiscal 2024 RevenueCOST Urges California High Court to Block Taxation of IntangiblesThe High Cost of Untaxed SalesSALT Cap Workarounds Are Not Always Beneficial, Practitioner SaysStakeholders: More Clarifications Needed for New Mexico's Digital Ad RulesVoters Reject Wealth Taxes in Texas, Approve Pot Tax in OhioNew and Revised Guidance on GILTI, FDII Available in New JerseyFollow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes**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 the Tax Attorney Recruiting Event. For more information, visit the-tare.com.***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige JonesShowrunner: Jordan ParrishAudio Engineers: Jordan Parrish, Peyton RhodesGuest Relations: Alexis Hart