Tax Notes Talk

Erika Isabella Scuderi, visiting assistant professor of tax law at the University of Florida’s Levin College of Law, discusses her proposal for establishing taxing rights in outer space. For more, read Scuderi's article, "On Sovereignty, Outer Space, and Taxation."**CreditsHost: David D. StewartExecutive Producers: Jeanne Rauch-Zender, Paige JonesProducer: Jordan ParrishAudio Editor: Laura Kondourajian****This episode is sponsored by Portugal Pathways. For more information, visit portugalpathways.io. This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Tax Notes contributing editor Robert Goulder discusses the Supreme Court's ruling invalidating the tariffs set in place by President Trump and what to expect for refunds. Subscribe to History Is Taxing today for free: taxnotes.co/historypodcastFor related tax news, read the following in Tax Notes:New Trump Tariffs Hit With Multistate Legal ChallengeANALYSIS: The Real Liberation Day: IEEPA Tariffs Go Down in Flames***CreditsHost: David D. StewartExecutive Producers: Jeanne Rauch-Zender, Paige JonesProducer and Editor: Jordan Parrish****This episode is sponsored by Portugal Pathways. For more information, visit portugalpathways.io. This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Tax Notes Talk presents History Is Taxing, our new podcast exploring the tax origins of today’s biggest topics, connecting the present to the past with tax experts Robert Goulder and Joseph J. Thorndike of Tax Notes. In this episode, Goulder and Thorndike explore how America’s first tariffs shaped the nation’s fiscal policy and set the stage for today’s federal income tax. Subscribe to History Is Taxing today for free: taxnotes.co/historypodcast***CreditsHost: David D. StewartExecutive Producers: Jeanne Rauch-Zender, Paige JonesProducer and Editor: Jordan ParrishSpecial thanks to Christopher Trigo and Carolyn Kuimelis for their help on this episode.****This episode is sponsored by Portugal Pathways. For more information, visit portugalpathways.io. This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Patrick Urda, Chief Judge of the U.S. Tax Court and former DOJ tax attorney, reflects on court administration and litigation trends. He discusses Dawson case management and evolving public access to documents. He also talks about the court’s approach to generative AI and how staffing shifts at the IRS affect litigation.

Tax Notes chief correspondent Stephanie Soong discusses the OECD’s recent pillar 2 side-by-side package deal and how countries are adapting to the new landscape. For related tax news, read the following in Tax Notes:U.S. Focusing on OECD Guidance for Pillar 2 Side-by-Side PackageHungary Expands Global Minimum Tax Registration FormU.S. Treasury Officials Declare Death of OECD Pillar 1***CreditsHost: David D. StewartExecutive Producers: Jeanne Rauch-Zender, Paige JonesProducers: Jordan Parrish, Peyton RhodesAudio Engineers: Jordan Parrish, Peyton Rhodes****This episode is sponsored by Portugal Pathways. For more information, visit portugalpathways.io. This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Rozeta Atlas, Director for Product Enablement and Adoption at HubSync, explains IRS digital modernization in plain terms. She covers automation vs staffing trade-offs. She flags privacy and cybersecurity risks with digitization. She explores AI uses for service and audits. She offers practical steps for firms to upgrade processes and data to keep pace.

Sarah Polcz, a law professor studying technology and policy, and Jeremy Bearer-Friend, a tax policy scholar, propose taxing generative AI firms via equity remittance to create partial public ownership. They discuss why tax can address societal harms, how an equity-paid tax could work, definitional and governance choices, historical precedents, and political and legal roadblocks.

Professor Andrea Campbell, author of Taxation and Resentment: Race, Party, and Class in American Tax Attitudes, discusses why Americans' beliefs about taxes often don’t align with the specific tax policies they support.For more on Taxation and Resentment, you can read Joseph Thorndike's book review here: "ANALYSIS: Why Do Americans Ignore Their Self-Interest When It Comes to Taxes?"If you're interested in hearing more about Andrew Kahrl's research on the property tax, check out our episode, "Tax or Theft? Examining the History of the Property Tax." ***CreditsHost: David D. StewartExecutive Producers: Jeanne Rauch-Zender, Paige JonesProducers: Jordan Parrish, Peyton RhodesAudio Engineers: Jordan Parrish, Peyton Rhodes****This episode is sponsored by Portugal Pathways. For more information, visit portugalpathways.io. This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Damien Martin, EY tax partner who analyzes major tax litigation, and Tony Nitti, EY tax partner and federal tax commentator, break down three pivotal 2025 cases about what counts as a deduction. They tackle whether nondeductible wages count for the 199A wage limit. They examine forgiveness versus worthlessness for bad debt claims. They dissect trade-or-business, capitalizing costs, and theft-loss timing issues.

Tax partners Tony Nitti and Damien Martin from EY dive into significant tax cases shaping 2025. They explore critical questions around what constitutes income, focusing on the CF Headquarters Corp. v. Commissioner and its implications for tax practitioners. Discussions include the nuances of tax presumption, the section 118 argument about non-shareholder contributions, and the complexities surrounding deductions for embezzlement claims in Franklin v. Commissioner. Expect fascinating insights into taxation that could impact both corporations and individuals alike.