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tax break is a podcast about tax law, brought to you by Miller & Chevalier, providing you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you’ll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting.
Episodes
Monday Mar 15, 2021
Monday Mar 15, 2021
Facebook is embroiled in a transfer pricing dispute with the IRS in Tax Court. This week on tax break, Steve and Loren conclude their discussion of what's at issue in the case. Listen to part 1 of the discussion in Episode 14.
Topics discussed:
- Basics of the dispute
- Whether aggregation of the three disputed royalties is reliable here
- Pricing the Platform Contribution Transaction royalty
- Challenge to validity of the -7T regulations
- Nature of the User Base and associated royalty
- Subsequent legal changes and changes to structure
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Questions? Contact us at podcasts@milchev.com.
tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you’ll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts.
Friday Mar 12, 2021
Friday Mar 12, 2021
This week, Steve and Loren discuss the results of the joint Miller & Chevalier and National Foreign Trade Council 2021 Tax Policy Forecast Survey with Miller & Chevalier Tax Member Marc Gerson.
View the survey here: https://bit.ly/taxpolicy2021
Topics discussed:
- Genesis of the survey
- Design of its questions
- Expectations for results
- Surprises in those results
- Other observations on the results
Thanks to our guest, Marc Gerson: https://www.millerchevalier.com/professional/marc-j-gerson
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Questions? Contact us at podcasts@milchev.com.
tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you’ll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts.
Monday Mar 01, 2021
Monday Mar 01, 2021
Facebook is embroiled in a transfer pricing dispute with the IRS in Tax Court. This week on tax break, Steve and Loren discuss what's at issue in the case.
Topics discussed:
- Basics of the dispute
- Whether aggregation of the three disputed royalties is reliable here
- Pricing the Platform Contribution Transaction royalty
- Challenge to validity of the -7T regulations
- Nature of the User Base and associated royalty
- Subsequent legal changes and changes to structure
*********
Questions? Contact us at podcasts@milchev.com.
tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you’ll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts.
Monday Feb 15, 2021
Monday Feb 15, 2021
The January special election in Georgia shifted control of the Senate to the Democrats. What does this mean for the prospects and content of future tax legislation? Hosts Steve Dixon and Loren Ponds are joined by their colleagues Jorge Castro and Marc Gerson to discuss:
- Contents of the Consolidated Appropriations Act, 2021
- New Composition of Finance and Ways & Means
- What Can Be Accomplished with Reconciliation?
- Possible Content of Reconciliation Vehicles
- Business Tax Proposals
Thanks to our guests:
Jorge Castro: https://www.millerchevalier.com/professional/jorge-e-castro
Marc Gerson: https://www.millerchevalier.com/professional/marc-j-gerson
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Questions? Contact us at podcasts@milchev.com.
tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you’ll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts.
Monday Jan 11, 2021
Monday Jan 11, 2021
This week on tax break, Steve and Loren are joined by Miller & Chevalier Tax Member Rocco Femia to discuss the recently proposed section 901 regulations’ net gain requirement and new jurisdictional nexus standard, as well as the implications of these modifications.
Thanks to our guest, Rocco Femia: https://www.millerchevalier.com/professional/rocco-v-femia
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Questions? Contact us at podcasts@milchev.com.
tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you’ll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts.
Friday Dec 18, 2020
Friday Dec 18, 2020
In a crossover with the Tax Notes Talk podcast, tax break host and Miller & Chevalier Member Loren Ponds shares her journey from Georgetown University Law Center to the OECD to Capitol Hill, where she worked on the 2017 tax law, and what she learned along the way. Loren is interviewed by Nana Ama Sarfo, who recently profiled her in Tax Notes' For the Love of Tax series. You can check out that profile here: http://bit.ly/PondsProfile
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Questions? Contact us at podcasts@milchev.com.
tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you'll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts.
Thursday Dec 17, 2020
Thursday Dec 17, 2020
On this episode of tax break, Loren and Steve are joined by Simon Webber, a managing director in the transfer pricing practice at Duff & Phelps, about the latest OECD initiatives and what they might mean for transfer-pricing valuation.
We'll speak about the endeavor of transfer pricing valuation as it relates to worldwide effective-tax-rate management, how the last round of OECD initiatives (under BEPS) changed the valuation landscape, and what might happen to that landscape with the two developing OECD pillars (the first of which contemplates some possible formulary apportionment among markets, the second of which contemplates a minimum tax that may be assessed on the basis of book financials).
Thanks to our guest, Simon Webber: https://www.duffandphelps.com/our-team/simon-webber
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Questions? Contact us at podcasts@milchev.com.
tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you'll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts.
Monday Nov 30, 2020
Monday Nov 30, 2020
In this episode of tax break, Steve and Loren are joined again by Miller & Chevalier tax Member Jorge Castro to discuss some of the business-specific tax proposals that have come from President-Elect Joe Biden. Jorge served on the Obama-Biden Transition Team in 2008 and provides perspective about how the incoming Biden administration is currently assessing these issues. We discuss significant general corporate changes, international tax changes, other domestic possibilities, and areas for bipartisan agreement.
Thanks to our guest, Jorge Castro: https://www.millerchevalier.com/professional/jorge-e-castro
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Questions? Contact us at podcasts@milchev.com.
tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you'll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts.
Monday Sep 28, 2020
Monday Sep 28, 2020
In this episode of tax break, Steve and Loren discuss the final FDII regulations from July 2020 with Sharon Heck, Treasurer and Chief Tax Officer at Intel.
They discuss several aspects of the business that have been affected by FDII, and policy discussion underscoring the importance of the provision now and going forward:
- Practical considerations (supply chain considerations, corollary to GILTI, impact to M&A transactions)
- Policy considerations (Biden tax proposals – Made in America, R&D innovation and incentivization, impact of impending R&D amortization provision)
Thanks to our guest, Sharon Heck: https://www.linkedin.com/in/sharonlheck/
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Questions? Contact us at podcasts@milchev.com.
tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you'll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts.
Monday Sep 14, 2020
Monday Sep 14, 2020
This week, Steve and Loren discuss the final FDII regulations from July with Jeff Tebbs, International Tax Counsel at Lockheed Martin. They cover:
- Allocation of R&E expenses, which Treasury did not address
- Finalized regulations treating 250(b) as operative under 861 allocation and apportionment rules
- Sales of general property that primarily contain digital content
- How final regulations relax documentation and substantiation requirements
Thanks to our guest Jeff Tebbs for joining us: https://www.linkedin.com/in/jtebbs/
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Questions? Contact us at podcasts@milchev.com.
tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you’ll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts.
Apple Podcasts: https://apple.co/2WAZXPy
Spotify: https://spoti.fi/2T9wJVW
Google Podcasts: https://bit.ly/3639emF
Stitcher: https://bit.ly/2Tpals3