Tax Notes Talk

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.

Philip Hwang, the Chief Tax Officer at Optima Tax Relief and national chair of the Taxpayer Advocacy Panel, shares insights on the looming 2026 filing season. He dives into the challenges taxpayers face, like refund delays and the impact of IRS staff cuts. Hwang highlights the shift toward digital refunds and the importance of reaching out to unbanked taxpayers. He also explains the new automatic first-time penalty abatement and offers advice on managing client expectations with upcoming changes.

Jaye Calhoun of Kean Miller discusses key tax issues that states will likely address in 2026, including One Big Beautiful Bill Act provisions and the adoption of artificial intelligence tools. For related tax news, read the following in Tax Notes:Iowa DOR Issues Withholding Guidance on OBBBA Tax DeductionsU.S. Chamber Backs Florida Bid to Challenge California Apportionment RuleStates to Face Budget, Tax Policy Questions in 2026 Conformity Debate***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.

In this engaging discussion, Jeremy Scott, Chief Operating Officer at Tax Analysts and a savvy tax policy analyst, dives into the whirlwind of U.S. tax developments from 2025 and speculates on 2026. He highlights the expansive OB-3 tax bill, detailing changes in individual rates and the implications for employers regarding tip deductions. Jeremy also sheds light on the evolving role of tariffs in revenue generation, underscores the IRS's staffing challenges, and predicts a politically charged legislative landscape ahead.

Trevor Sykes, a Tax Notes legal reporter, dives into the intriguing exclusion of tips for pornographic activities and the complexities of platforms like OnlyFans. Nathan Richman discusses the intense legal saga around Ian Freeman's crypto church tax convictions, highlighting the court's stance on willfulness. Amanda Athanasiu explores the implications of marital discord in FBAR cases, illustrating that hiding accounts from a spouse isn't an acceptable excuse. Emily Hollingsworth reports on Hasbro's significant tax credits tied to their move to Boston, revealing state tax strategy dynamics.

Vanessa Williamson, a political scientist at the Brookings Institution and author of The Price of Democracy, discusses how taxation intertwines with democracy in American history. She reframes the Boston Tea Party as a fight against corporate interests rather than simply anti-tax sentiment. Williamson highlights the civic pride in paying taxes as a civic duty and explores how tax debates often target marginalized groups. She advocates for a fair and sufficient tax system to support democratic values, emphasizing the need for responsible leadership.

Tax Notes reporters discuss updates on the biggest tax issues of the year, including the expiring Affordable Care Act credit and the Trump administration's recent tariff and trade announcements.For related tax news, read the following in Tax Notes:Senate Set to Reject Dueling Bills, Leaving ACA Credit in LimboNew Guidance Provided on Expanded HSA EligibilityTrump Threatens Mexico With Tariffs Over Texas Water SpatHouse GOP Pushes Trump to Revive Tariffs on France Over DST**This episode is sponsored by Avalara. For more information, visit avalara.com.This episode is sponsored by Crux. For more information, visit cruxclimate.com/contact.***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.

Trudy Muscat of Deloitte Malta discusses Malta's changing international tax landscape, including its adoption of the two-pillar system and recently implemented transfer pricing rules. For more episodes from Lisbon, listen to:From Lisbon: The Search for Consensus on International TaxFrom Lisbon: The Future of International Tax CooperationFrom Lisbon: Portuguese Tax Administration in the Digital AgeFrom Lisbon: Highlights From the 2025 IFA CongressFor related tax news, read the following in Tax Notes:Bulgarian Parliament Approves Tax Treaty With MaltaEU’s Tax Priorities Shift as Reform Stalls, Researchers SayMNE Profit Shifting Still Persistent, OECD Report Says***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.

Juan Manuel Vázquez of Loyens & Loeff discusses the evolving international tax agenda, including ongoing pillar 2 negotiations and taxing the digital economy.For more episodes from Lisbon, listen to:From Lisbon: The Future of International Tax CooperationFrom Lisbon: Portuguese Tax Administration in the Digital AgeFrom Lisbon: Highlights From the 2025 IFA CongressFor related tax news, read the following in Tax Notes:G20 Leaders Affirm Goal for OECD Global Minimum Tax AccordIf Pillar 2 Directive Reopens, EU Won’t Close It, Official SaysOECD Talks on U.S. Pillar 2 Exemption Focused on SimplificationItaly Defends DST and Urges OECD to Restart Digital Talks***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.

Tax Notes reporters Cady Stanton and Benjamin Valdez discuss the tax credit debate that led to the government shutdown and the potential effects on the IRS and the 2026 filing season. For related tax news, read the following in Tax Notes:Democrats Say It's Too Late for Any ACA Credit AlternativeShutdown May Hinder Filing Season Timeline, Former IRS Chiefs SayRepublican Leaders Harden Stance Against ACA Tax Credit**This episode is sponsored by Avalara. For more information, visit avalara.com.***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.