Podcasts by tax break

Implications of the Proposed Digital Asset Reporting Regulations | tax break #25 from 2023-10-24T15:51

This week on tax break, host Rob Kovacev and guest John Schoenecker, Government Relations and Regulatory Strategy Director of TaxBit, discuss the recently proposed regulations under IRC 6045, pa...

IRS ADR Procedures with George Hani | tax break #24 from 2023-09-08T12:35:46

This week on tax break, host Rob Kovacev interviews fellow Miller & Chevalier Tax Member George Hani on the various procedures the IRS offers for resolving tax disputes short of litigation. ...

The IRS Strategic Operating Plan – A Conversation with Larry Gibbs | tax break #23 from 2023-06-22T10:38:52

This week on tax break, host Rob Kovacev is joined by former IRS Commissioner and Miller & Chevalier Senior Counsel Larry Gibbs to discuss the IRS's Strategic Operating Plan and where the IRS sh...

Tax Enforcement Under State False Claims Acts | tax break #22 from 2023-04-12T13:26:09

This week, host Rob Kovacev is joined by Miller & Chevalier colleagues Joe Rillotta and Ian Herbert to discuss tax enforcement under state False Claims Acts.  

The False Claims Act has be...

What Taxpayers Need to Know About the IRS’s New Requirements for Filing for R&E Credit Refunds | tax break #21 from 2022-08-04T12:05:40

And we're back! In our season 2 premiere, hosts Loren Ponds and Rob Kovacev discuss the latest Chief Counsel Advice Memorandum outlining more burdensome procedures for taxpayers requesting R&E c...

Liberty Global: The First Challenge to the 245A Regs | tax break Episode 19 from 2021-06-21T00:00

With the action by Liberty Global in November of last year, we have the first challenge to the validity of the Temporary Regulations under section 245A. We discuss those regulations and some of ...

American Jobs Plan Calls for Major Changes to the International Tax Landscape | tax break Episode 18 from 2021-04-20T14:13:46

Loren and Steve will discuss the tax proposals included in the American Jobs Plan, which are meant to fund large infrastructure investments the Biden administration plans to make.

Topics ...

Insights on Transfer Pricing Valuation | tax break Episode 17 from 2021-03-29T11:23:01

In this episode, Loren and Steve speak with Mike Cragg from The Brattle Group about economics and transfer pricing valuations. 

Over time, the modes of economic valuation for transfer pri...

Breaking Down Facebook’s Litigation in the Tax Court, Part 2 | tax break Episode 16 from 2021-03-15T14:10:45

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 ...

The 2021 Tax Policy Forecast Survey | tax break Episode 15 from 2021-03-12T11:47:44

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.<...

Breaking Down Facebook's Litigation in the Tax Court, Part 1 | tax break Episode 14 from 2021-03-01T16:00:28

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:

• B...
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Tax Legislation in the New Congress | tax break Episode 13 from 2021-02-15T00:00

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 P...

Proposed Section 901 Regulations – Creditability Reimagined | tax break Episode 12 from 2021-01-11T00:00

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 jurisdictio...

Loren Ponds Talks Secrets to Success and Writing Tax Reform | tax break x Tax Notes Talk from 2020-12-18T14:42:32

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, whe...

OECD Initiatives and Transfer Pricing Valuation | tax break Episode 10 from 2020-12-17T13:51:12

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 m...

Biden Tax Plan | tax break Episode 9 from 2020-11-30T11:13:48

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-...

Final FDII Regulations: Part 2 | tax break Episode 8 from 2020-09-28T00:00

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...

Final FDII Regulations: Part 1 | tax break Episode 7 from 2020-09-14T00:00

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 T...
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Section 199A: Everything You Ever Wanted to Know... and Probably Some Things You Didn't | tax break Episode 6 from 2020-07-27T14:29:39

On this episode, hosts Loren Ponds and Steve Dixon discuss with our esteemed guest, Andy Howlett (Tax Member at Miller & Chevalier), some of the finer points of Section 199A. 

Section 199...

What Does DACA Have to Do with Cost-sharing Regulations? | tax break podcast Episode 5 from 2020-07-13T00:00

In this episode, Loren and Steve discuss the APA, what it means for Treasury Regulations, and the APA issues presented in the Altera case.

The Supreme Court just denied Altera's petition ...

Microsoft Loses Its Work Product and Privilege Dispute | tax break podcast Episode 4 from 2020-06-29T00:00

In this episode of tax break, hosts Loren Ponds and Steve Dixon are joined by guest Kevin Kenworthy (Chair of Miller & Chevalier's Tax Department) to discuss the upshot of the district court's d...

Select Issues in the BEAT Regulations (Part 2) | tax break podcast Episode 3 from 2020-06-15T00:00

In this episode of tax break, hosts Loren Ponds and Steve Dixon conclude their discussion of a couple of notable issues raised by the final and proposed base erosion and anti-avoidance tax (BEAT...

Select Issues in the BEAT Regulations (Part 1) | tax break podcast Episode 2 from 2020-06-01T00:00

In this episode of tax break, hosts Loren Ponds and Steve Dixon discuss a couple of notable issues raised by the final and proposed base erosion and anti-avoidance tax (BEAT) regulations issued ...

Pandemic Relief Legislation for Businesses | tax break podcast Episode 1 from 2020-05-18T00:00

In the first episode of tax break, hosts Loren Ponds and Steve Dixon are joined by guest Jorge Castro (Member at Miller & Chevalier and former Counselor to the IRS Commissioner) to discuss the t...

Welcome to tax break from 2020-03-09T19:12:32

tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon...