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Tax Notes TalkLess Is Moore: The Supreme Court's Ruling in Moore v. United StatesSend us a textTax Notes managing legal reporter Andrew Velarde breaks down the Supreme Court's decision in Moore v. United States and its implications for the future of tax.To hear from the Moores' lawyers, watch the upcoming Taxing Issues webinar here.Listen to our previous 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:Moores' Counsel Says Case Signals Court Is Not Open to Novel Tax...2024-06-2813 minTax Notes TalkLiberty Global and the Economic Substance DoctrineSend us a textTax 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 Doctr...2024-02-0215 minTax Notes TalkA Recap of SCOTUS Oral Arguments in Moore v. United StatesSend us a textTax Notes managing legal reporter Andrew Velarde breaks down the Supreme Court's oral arguments in Moore and predicts what's next for the case.For additional coverage, read these articles in Tax Notes:Government May Have Upper Hand in Moore, but Court May Go NarrowMoore Sold Shares in Transition Tax Company for Big GainMoores Fire Back That Macomber Is Controlling, Not Mere DictumTransition Tax Drafter: Quit It With ‘Mandatory Repatriation Tax’Small Business Groups Enter the Moore Fray in Defense of the TaxMoore Amicus Offers Supreme Court Off-Ramp From Realization QueryMacomber Dictum Not...2023-12-1530 min
South Phoenix Oral History Project3.9 "Reading Places of Their Own"Welcome back to the "South Phoenix Oral History Project" after a rejuvenating summer break! In Episode 9, your hosts Summer and Ele kickstart the season with an enlightening discussion about Andrew Wiese's groundbreaking work, "Places of Their Own: African American Suburbanization in the Twentieth Century."The cozy image of suburbia often doesn't conjure associations with African-American communities. However, Wiese's pioneering research challenges this notion, revealing a century-long history of black residents in the suburbs, a population that has nearly doubled to nearly twelve million in recent decades. "Places of Their Own" takes us...2023-11-0724 minTax Notes TalkAn Update on the Foreign Tax Credit Rules and IRS ReliefSend us a textTax Notes reporter Andrew Velarde discusses the latest developments on the final regulations for claiming foreign tax credits, including the IRS’s decision to delay implementation and the tax community’s response. For more on the foreign tax credits, listen to "The Final Foreign Tax Credit Rules: Complaints and Confusion."For additional coverage, read these articles in Tax Notes:IRS Says It Anticipates Extending FTC Relief Notice Another YearTreasury to Publish FTC Guidance on Pillar 2 Taxes by Year-EndGOP Taxwriters to Air Grievances to OECD Leaders in EuropeSilicon Valley Asks...2023-09-1517 minTax Notes TalkMoore Money, More Tax Problems? Analyzing Moore v. United StatesSend us a textProfessor Hank Adler of Chapman University discusses the income realization requirement dispute in the transition tax case Moore v. United States before the Supreme Court, and its implications on the U.S. tax system. For additional coverage, read these articles in Tax Notes:News Analysis: Limiting the Fallout From MooreSupreme Court to Hear Transition Tax Case With Vast ImplicationsFollow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes***CreditsHost: David D. StewartExecutive Producers: Jasper B. Smith, Paige Jones2023-07-2126 minTax Notes TalkTaxpayer Scores: Farhy Blocks International Reporting PenaltiesSend us a textTax Notes reporter Andrew Velarde discusses the penalty dispute in Farhy v. Commissioner and the case’s implications for other penalties and future refund decisions. For additional coverage, read these articles in Tax Notes:In Farhy’s Wake, Taxpayer Advocate Renews Call for Penalty ChangeFallout From Farhy on Assessable Penalties Could Be ExtensiveIRS Lacks Assessment Authority for Information Return PenaltiesInformation Return Penalty Assessment Controversy Still SwirlsInformation Return Penalty Assessment Fight Coming to a HeadFollow us on Twitter:David Stewart: @TaxStewTax Notes: @TaxNotes***Credits...2023-05-0513 minTax Notes TalkWhirlpool Sends the Tax World SpinningSend us a textTax Notes reporter Andrew Velarde discusses the tax structure dispute in Whirlpool v. Commissioner and the case’s future implications for multinational companies. For additional coverage, read these articles in Tax Notes: No Full Court Rehearing for Whirlpool, Sixth Circuit SaysWhirlpool Agitated Over Attempt to Brand It a Tax CheatParts Manufacturer Sees Daylight Between Itself and WhirlpoolDOJ Urges Circuit to Reject Whirlpool’s Call for RehearingGroups Line Up to Warn Circuit About Whirlpool FalloutWhirlpool Wants Circuit to Give Branch Income Case Another SpinWhirlpool’s Circuit Court Loss Could Cost It $95 Million...2022-03-1822 min
Sounding BoardThe What’s Worse Game: Dad EditionAfter listening to the first What’s Worse Game, our Dad couldn’t resist getting in on the action, and so came up with a new list of competing horrors for Nic to challenge Andrew with.
The aim of the game is to pick the worst of the two options – not the least worst – and then explain why.
There are some absolute corkers in this week’s version of the Worst Game, and we cover such lovely topics as slavery, the BBC and Sadiq Khan.
Photo by Guillermo Velarde on Unsplash
Please visi...2021-07-2933 min
RUMBO A TU VIDAEp. 24: El papel de la religión en la sociedad hoy en día.En el episodio de hoy abordamos cuál es el papel que tiene la religión hoy en día, en una sociedad con muchísima tecnología y con personas que, cada vez más , se hacen preguntas sobre su origen,rumbo, metas, etc.Manolo Velarde, biólogo y cristiano, quien completó el Trienio Básico de Teología en el Instituto San Pío X viene a nuestro podcast a charlar sobre el papel de la religión en la sociedad hoy en día y a contestar a preguntas que todos nos hemos hecho en algún momento.Nuestra...2021-01-1529 minTax Notes TalkThe Impact of the 2020 U.S. Elections on International TaxSend us a textTax Notes senior legal reporter Andrew Velarde and contributing editor Robert Goulder discuss the influence of the 2020 U.S. elections on the international tax world. For additional coverage, read these articles in Tax Notes:Biden’s International Tax Proposals Missing Many PiecesEU Hopes to Repair Bilateral Relationship With U.S.Biden Win Brings Hope for Progress in Global Tax TalksTaxOps SALT expert Tram Le talks about her recently published piece, “Simplification Initiatives to Reduce Burdens for Remote Sellers.”**This episode is sponsored by Avalara. For more i...2020-11-2040 minTax Notes Talk2020 Foresight: Tax Legislation and RegulationsSend us a textTax Notes's Jeremy Scott, Stephanie Cumings, and Andrew Velarde review what happened with tax legislation and guidance in 2019 and what lies ahead in 2020.For additional coverage, read these articles in Tax Notes:Conservatives Worry TCJA Could Be Death Blow to Future Tax CutsSenate Sends $426B in Tax Cuts to Trump's DeskA Look Ahead: Democrats to Stand Behind Wealth Taxes in 2020A Look Ahead: Eyes Still on TCJA International GuidanceA Look Ahead: Parking Regs Should Address Fair Market ValueA Look Ahead: Carried Interest and Form Changes Will Be Focus for Partnerships2020-01-0324 minTax Notes TalkBehind the Scenes of OIRA and Draft TCJA RegsSend us a textJonathan Curry and Andrew Velarde discuss the draft regulations Tax Notes obtained from the Office of Information and Regulatory Affairs.For additional coverage, read these articles in Tax Notes:New OIRA Drafts Reveal Tweaks to TCJA GuidanceOIRA Leadership Shuffle Opens Door to Tax Reg Review Shake-UpOIRA’s Tax Reg Reviews Remain a ‘Black Box’ Despite Draft RegsSpotlight on OIRA’s Review Process Eases Politicization ConcernsOIRA’s Imprint on Tax Regs Revealed in New Cache of Documents***This episode is sponsored by University of California, Irvine Law School’s G...2019-07-1920 min