KPMG's This Week in State Tax (TWIST)

Introducing KPMG's TWIST This Week in State Tax, a new tool from KPMG's State and Local Tax practice to help keep you up to date on the latest in state and local tax. TWIST features a series of short podcasts hosted by our Washington National Tax professionals who will cover state and local tax developments dating from the previous week.

Rank #1: Iowa: Department addresses post-Wayfair sales tax nexus standard.
The Iowa Dept. of Revenue recently issued a declaratory order addressing whether a taxpayer was required to collect and remit Iowa sales tax.

Rank #2: Alabama: Canned and Custom Software is Taxable Tangible Personal Property.
The Alabama Supreme Court recently held that Alabama sales and use tax law does not distinguish between canned and custom software for purposes of taxability.

Tax Foundation's Tax Policy Podcast

The Tax Policy Podcast is the official podcast of the Tax Foundation, a non-partisan, non-profit research organization that has monitored tax policy at the federal, state and local levels since 1937. Our economists welcome your feedback via email: podcast@taxfoundation.org.

Rank #1: Jon Caldara on Gov. Hickenlooper's Tax Record in Colorado.
Independence Institute president Jon Caldara comments on Gov. John Hickenlooper's tax policy in Colorado and the findings of a public advisory panel that has claimed wide support for an income tax increase in the state.

Rank #2: Joseph Henchman on the Supreme Court's Health Care Ruling.
Tax Foundation Vice President for Legal & State Projects Joseph Henchman discusses the impact of the Supreme Court's verdict on the Patient Protection and Affordable Care Act.

Corporate Tax Planning

Covers C (regular) corporate taxation and planning including taxation of shareholders

Rank #1: How Much to Tell--Adequate Disclosure and Section 6501(e) - Ed Zollars.
This PodCast uses the case of Benson v. Commissioner, TC Memorandum 2006-55, to examine the issue of what constitutes adequate disclosure under Section 6501(e)(1)(A)(ii) for purposes of avoiding the otherwise mechanical application of an extended six year statute on substantial underpayments.  In this case, which the taxpayer ends up losing, the Court considers to what extent disclosures on other returns can "make up" for items not disclosed directly on the individual return.The text file for this podcast can be downloaded from http://www.edzollars.com/2006-04-08_Adequate_Disclosure.pdf.This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

Rank #2: Whose Debt Is It Anyway? S Corporations and Loans from Related Entities - Ed Zollars.
This Podcast is about loans, S Corporations, and reality engineering. Shareholder debt to S corporations has proven to be a minefield for shareholders and their advisers, and the taxpayer and their adviser in the case of Ruckriegel v. Commissioner managed to step on a shareholder debt/basis mine twice in two consecutive IRS exams.  In this case, the shareholders attempted to argue that loans from a partnership they controlled were actually loans to them from the partnership, followed by loans to the corporation.Or, to put it more correctly, their CPA attempted to argue that.  One of the problems in this case, beyond the simple fact that the form of the transaction (which the taxpayers had control over) did not agree with what they were arguing was the true substance, was the fact that neither the taxpayers nor their inside accountant were treating these loans as if they had traveled that indirect route.  The case points up the dangers of attempting to "after the fact" correct client missteps--and especially continuing to do it for multiple years.The materials for this podcast are found at http://edzollars.com/2006-04-29_Debt.pdf.This Podcast is sponsored by Leimberg Information Services, Inc. at http://www.leimbergservices.com Please visit our software, books, and PowerPoint Presentations site at http://www.leimberg.com

Tax Readiness

Our panel of business specialists, from across the PwC network, share perspectives on the implementation and impact of tax reform on your business as well as discuss the future of tax. From financial reporting to workforce strategies and tax function preparedness, listen in to help you stay current. You can listen to episodes at your convenience via your desktop computer or smart phone.

Rank #1: Tax Readiness: State tax reform implication - Part 1.
In this tax readiness podcast PwC State Tax Partners Erick Burkheiser, Jim Manley, and Tina Skidmore, and International Tax Services Partner, Rebecca Lee discuss certain provisions of federal tax reform that have significant impacts at the state tax level.

Rank #2: Tax reform readiness: US base erosion an anti-abuse tax (BEAT) - Part 1.
This podcast consists of a discussion between PwC professionals Ken Kuykendall, Quyen Huynh, Tom Quinn, and Paige Hill on the statutory framework of the BEAT, including how the rules generally work.

EY Cross-Border Taxation Alerts

The EY Cross-Border Taxation Podcast series brings you the latest developments in major international tax news from around the globe.

Rank #1: EY Cross-Border Taxation Spotlight for Week ending 02 March 2018.
A review of the week's major US international tax-related news. In this edition: US House Ways & Means Committee Chairman expects series of small, technical corrections bills to TCJA -- House Ways and Means Tax Policy Subcommittee will hold hearing on tax extenders on 14 March – Senior Treasury tax official resigns.

Rank #2: EY Cross-Border Taxation Spotlight for Week ending 25 October 2019.
A review of the week's major US international tax-related news. Update on US international guidance at OMB OIRA – IRS to continue scrutiny of virtual currency transactions – IRS concludes Section 952(c) election to include excludible insurance income in subpart F income of CFCs’ US shareholder is obsolete – G20 expresses support for OECD’s two-pillar approach.

aicpataxe-alert's Podcast

Rank #1: AICPA Tax eAlert - February 6, 2009.
This is an expanded version of the e-alert that was sent to AICPA Tax Section members in the last week. Links to the documents referred to in this podcast are available in the emailed version which AICPA members can receive by joining the Tax Section at service@aicpa.org or 888-777-7077.

Rank #2: AICPA Tax eAlert - October 27, 2009.
This is an expanded version of the e-alert that was sent to AICPA Tax Section members in the last week. Links to the documents referred to in this podcast are available in the emailed version which AICPA members can receive by joining the Tax Section at service@aicpa.org or 888-777-7077.

Federal Tax Update Podcast

Federal Tax Update Podcast Series

Rank #1: 2018-09-24 Is This Reasonable?.
This week we look at the following items: Tax Court allows a taxpayer to try and prove reasonable reliance on indirect legal advice Updated safe harbor explanations for plan distributions issued by IRS IRS delays major revision to Form W-4 to 2020 Relief announced for victims of Hurricane Florence Copyright 2018, Kaplan, Inc.

Rank #2: 2018-09-17 Are 349 Filings Unconstitutional?.
This week we look at the following items: South Dakota enacts remote seller law to implement Wayfair decision beginning November 30 Colorado tests the limits of Justice Kennedy’s holdings in Wayfair Even though records were imperfect, Tax Court finds the taxpayer was a real estate professional Opportunity Zone regulations at OMB, expected out around the end of the month IRS rules math error procedures can be used even after refunds are issued Copyright 2018, Kaplan, Inc.

U.S. Tax Court Podcast

Podcast by Rik Thakrar and Lee Wilson

Rank #1: Episode 1 - Branerton Corp. v. Commissioner, 61 T.C. 691 (1974).
In this episode, Rik Thakrar and Lee Wilson discuss Branerton Corp. v. Commissioner and the Tax Court's use of informal discovery.

Rank #2: Episode 2 - Golsen v. Commissioner, 54 T.C. 742 (1970) - Part 1.
In this episode, Rik Thrakar and Lee Wilson begin discussion the landmark case of Golsen v. Commissioner and appellate review o Tax Court cases. This episode discusses how the history of the U.S. Tax Court and cases such as Lawrence v. Commissioner, 27 T.C. 713 (1957), influenced the decision in Golsen.

Ernst & Young ITS Washington Dispatch

The Ernst & Young ITS Washington Dispatch brings you the latest developments in US tax news.

Rank #1: ITS Washington Dispatch, November 2018.
Congress returns for lame-duck session; year-end tax bill taking shape – IRS releases proposed regulations and related guidance on interest expense limitation under Section 163(j) – IRS issues proposed foreign tax credit regulations – IRS releases draft Form 8990, Limitation on Business Interest Expense under Section 163(j) – Taxpayers told to expect more ‘informal’ guidance, including on cryptocurrencies – IRS adds four new LB&I international compliance campaigns – US, Japan sign CbCR information exchange arrangement – Netherlands to repeal decree re: US-Netherlands tax treaty regarding hybrid entities – OECD issues guidance on MLI synthesized texts, MLI entry into effect – OECD updates results on preferential tax regimes, substantial activity requirements for no/nominal tax jurisdictions – OECD begins new BEPS Action 14 minimum standard review of additional jurisdictions

Rank #2: ITS Washington Dispatch, August 2018.
US Treasury releases proposed Section 965 regulations on repatriation transition -- IRS proposed GILTI regs under review by OMB; draft GILTI and FDII forms released -- IRS announces upgrades to FATCA Registration System – US Tax Court holds upstream loan between CFCs was bona fide debt, later transfer of proceeds to US shareholders nontaxable return of capital - DC Circuit rejects per se bar on bearer shares under Section 883 income exclusion for international shipping and aircraft corporations - Ninth Circuit withdraws opinion reversing Tax Court in Altera — US Tax Court rules Section 1446 W/H tax liability is a partnership item -- Eighth Circuit vacates Tax Court opinion in Medtronic, remands to Tax Court for further consideration -- OECD releases fourth batch of peer review reports on Action 14

Taxology

This is Taxology, the podcast where experts from the non-partisan Tax Policy Center decode the tax code, translate the jargon, and do the math. Think of us as tax geeks in search of truth.

Rank #1: Do Tax Cuts Pay for Themselves?.
The White House aims to enact historically big tax cuts and claims they would not add to the federal deficit because they would stimulate the economy and pay for themselves. On this episode of Taxology, we explore the theory and history behind this approach to formulating tax policy: the Laffer Curve.

Rank #2: The Stars Align: the 1986 Tax Reform.
As the 115th Congress weighs tax reform policy, Taxology takes a look back at the last time the United States actually enacted substantive tax reform. A conversation with Eugene Steuerle, Janice Mays, and Howard Gleckman reveals what was happening behind the scenes at the time and what lessons current lawmakers and White House officials can use going forward.

Tax Notes Talk

A discussion of cutting-edge developments in tax, including up-to-the-minute changes in federal, state, and international tax law and regulations.

Rank #1: Business Loss Deduction Complications.
Richard Joslin, a consultant to EnTrustPermal, discusses how the new business loss and interest expense limitations work together and affect other code provisions.For more details, read Joslin's article in Tax Notes.

Rank #2: Death Taxes.
Joseph Thorndike, director of the Tax History Project, explains the history of estate and inheritance taxes and how they became so unpopular.For additional coverage, read these article in Tax Notes:Tax History: The Century of the Estate Tax: Made for Revenue, Not RedistributionTax History: The Not-So-Puzzling Unpopularity of the Estate TaxTax History: When Estates Were (Almost) Taxed as Income

Current Federal Tax Developments

Weekly update on federal income tax developments

Rank #1: 2018-10-28 Denied Deduction Not Excessive Fine.
Current Federal Tax Developments for the week of October 28, 2019: Denied Deduction Not an Excessive Fine California rules on tax issues for directors that have meeting in California Chief Counsel’s office gives guidance on use of secured email exchanges §280E found not to represent an excessive fine even if the Tax Court doesn’t completely agree on why Interim guidance issued to Appeals employees on BBA partnership regime Whistleblower cannot force IRS to reopen an audit that he claimed was woefully inadequateAn audio only version of the broadcast can be streamed or downloaded below: This week’s articles can be downloaded as a PDF from the link below:2018-10-28 Current Federal Tax Developments

Rank #2: 2019-11-04 Both a Home and An Investment.
Current Federal Tax Developments for the week of November 4, 2019 Both a Home and an InvestmentWisconsin fails in attempt to look to sublease to tax software sales based on computers sold to be used in the stateIRS agrees that taxpayer qualifies for both §121 and §1031 for the sale of a former home destroyed by fireDraft Form 1065 and K-1 instructions released by the IRSAn audio only version of the broadcast can be downloaded below: Articles for this week’s update can be downloaded in the PDF below.2019-11-04 Current Federal Tax Developments

Talking Tax

A podcast series discussing the big issues for UK tax and fiscal policy that everyone should debate.

Rank #1: Episode 4 - US Tax Reform - Why it's a big deal?.
One of the biggest tax stories of recent months has been the sweeping changes being made to the US tax system. It's clear that when the world's biggest economy makes significant tax changes, it's a big deal worldwide, the effects are far-reaching and could affect all of us. What are the implications for policy makers, and what should businesses be aware of? Barry Murphy, Partner at PwC explores in conversation with Tom Pattern, a US Tax Partner in PwC and Will Morris, our Deputy Global Tax Policy Leader at PwC.

Rank #2: Episode 5 - What’s the deal with hypothecated taxes?.
It’s not a new concept, but tax hypothecation is back under the spotlight. Most recently it’s been discussed to address the challenge of funding the rising demand on health and social care services in the UK. How can you understand the benefits and drawbacks? Are there ways in which it might be an useful addition to the Chancellor’s tool box? Listen to Tax Partner, Barry Murphy, Stella Amiss, Head of Tax Policy and Caroline Macfarland, Director at Common Vision (CoVi) discuss and explore some of the findings of PwC sponsored CoVi report on hypothecated taxes.

Tax Function of the Future

Our PwC tax specialists share perspectives on tax's role in the world's business environment of today and tomorrow. Listen in as they delve deeper into new predictions for the role of tax in a changing tomorrow. You can listen to episodes at your convenience via your desktop computer or smart phone.

Rank #1: Tax Function of the Future: How tax is leveraging AI in 2019.
On this Tax Function of the Future podcast, PwC's Andy Ruggles talks with Jake Wilson and Hadley Leach discuss the Fourth Industrial Revolution and how its impact extends to enabling areas such as Finance and Tax.

Rank #2: Tax Function of the Future: Legal entity forecasting and the importance of transfer pricing.
On this Tax Function of the Future podcast, PwC's Andy Ruggles and David Nickson discuss is the importance of transfer pricing and inter-company accounting and how it fits into forecasting the legal entity income information.

Ed Zollars' Tax Update Podcast

Tax matters updated (hopefully) regularly

Rank #1: A Defining Moment-Brokerage Trade or Business.
The IRS has shown recent interest in disputing whether real estate agents meet the requirements to be treated as real estate professionals that can use the rules of §409(c)(7) to treat rental real estate under the standard passive activity rules rather than having such items automatically treated as passive.  The IRS position is that since the law refers to a "brokerage" trade or business and such individuals generally are not licensed as real estate brokers they cannot qualify.In the case of Agarwal v. Commissioner, TC Summary 2009-29, the Tax Court did not agree with the IRS on that matter, instead allowing the taxpayer, who was a real estate agent who worked as an independent contractor under contract with a licensed brokerage firm, to qualify for §409(c)(7) treatment.  The podcast also discusses a 2007 case where it was the IRS who was (successfully) arguing that you can't use state law licensing definitions when the issue was whether an bookkeeping and tax preparation firm that was not licensed as a CPA firm was a personal service corporation.  In both of these cases, the Tax Court found that under the IRC we would look to the commonly understood definition of the terms, and that state licensing definitions did not control.Materials for this podcast can be found at http://www.edzollars.com/2009-03-09_RealEstate.pdf .The podcast is sponsored by Leimberg Information Services, located at http://www.leimbergservices.com .

Rank #2: Sharing the Credit-IRS Rules on Section 36 Provision.
Last year when Congress added the first-time homebuyer credit found in Section 36, they included the ability for unmarried individuals who jointly acquire a residence to allocate the credit among themselves, and gave the IRS the ability to write the rules to allow this to happen.  In Notice 2009-12 the IRS has outlined those rules, and they proved to be very taxpayer friendly.The materials for the podcast can be downloaded at http://www.edzollars.com/2009-01-20_UnmarriedCredit.pdf .The podcast is sponsored by Leimberg Information Services, located on the web at http://www.leimbergservices.com .