Episodes

  • Making Sense of the Global Tax Carve-Out for US Companies

    Making Sense of the Global Tax Carve-Out for US Companies
    Jan 7 2026
    The OECD just published the parameters of a deal that would exempt US companies from two key enforcement rules in the global minimum tax framework. The deal, which spans 88 pages in the form of administrative guidance, includes a slew of safe harbor rules that address everything from how US companies can get the exemption to more advantageous treatment of substance-based tax incentives like the US R&D credit. It includes a permanent, simplified global minimum tax calculation. Other countries would be able to obtain carve-outs like the ones obtained by the US and its multinational companies—if they meet certain criteria. This week on Talking Tax, reporters Lauren Vella and Somesh Jha discuss why the deal and the timing of its release is important, what it means for multinational businesses, how key US lawmakers reacted, and what the deal means for the efficacy of the global minimum tax going forward. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
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    16 mins
  • How Transfer Pricing Offers a Fix for Student Athletes (Rerun)

    How Transfer Pricing Offers a Fix for Student Athletes (Rerun)
    Dec 31 2025
    We're off for the New Year holiday, so we're serving up an encore presentation of a Talking Tax podcast about challenges with paying student athletes. Ever since student athletes gained the right to be compensated for use of their image in advertisements and merchandise sales, the money has flooded in, but so have some problems. The athletes can now be compensated for their name, image, and likeness—or NIL—but schools still can’t directly pay them for playing. Instead, athletes can receive compensation when merchandise with their name or number is sold, or for showing up in advertisements or social media posts for businesses. But the line between legitimate NIL and illegitimate pay-for-play can get blurry. On this episode of Talking Tax, University of Kentucky professor Stephen Lusch talks with reporter Caleb Harshberger about how transfer pricing and tax law concepts can show whether the deals are done at reasonable prices that really reflect the value the student brings. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
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    14 mins
  • PwC Coaches New Tax Associates on AI Tools in US Training Effort

    PwC Coaches New Tax Associates on AI Tools in US Training Effort
    Dec 23 2025
    PwC's new training program aims to give early-career recruits hands-on experience integrating artificial intelligence tools into everyday work. The Big Four accounting and advisory firm started piloting AI immersion sessions in October, with a full rollout to new US associates slated for July. The sessions are happening across PwC's tax, assurance, and advisory business. "We truly believe that the role of the new associate will be changing with AI and that their role will become somewhat elevated, and we need to make sure that we're really training them on those skills to work and think differently," said Margaret Burke, the firmwide talent acquisition and development leader for PwC US. Like its competitors, PwC has recently funneled resources into next generation autonomous tools aimed at handling routine tasks solo. The firm said in November it shed about 150 jobs across marketing, human resources, and other US support roles as part of a longer-term effort modernizing its back-office unit, including through using new AI tools. In this week's Talking Tax, Burke and PwC US Tax Leader Krishnan Chandrasekhar sat down with Bloomberg Tax reporter Jorja Siemons to discuss how the AI trainings have gone so far and what skills they hope new employees learn. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
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    17 mins
  • Tariffs, Big Audits, Roil Transfer Pricing Heading Into New Year

    Tariffs, Big Audits, Roil Transfer Pricing Heading Into New Year
    Dec 10 2025
    A slew of big tax disputes and the worldwide upheaval brought on by the Trump administration's aggressive trade policy made for an exceptionally interesting year for transfer pricing professionals, and left them with lingering questions heading into 2026. President Donald Trump's April tariff announcements sent shock waves through the global economy and forced corporate tax heads—and C suites—to start figuring out what it all meant for their tax and transfer pricing positions, and whether they needed to make changes to fend off potential audits. At the same time, companies are seeing a growing number of audits and transfer pricing disputes—often with big dollar figures—as tax authorities around the world beef up their auditing and enforcement capabilities with staff, AI, and stronger reporting requirements. Auditing multinationals can bring them big tax rewards. That might be less true at the IRS, where the Trump administration has drastically reduced resources and staffing. On this episode of Talking Tax, Bloomberg Tax transfer pricing reporter Caleb Harshberger discusses what's been going on in the world of transfer pricing—which governs transactions within corporate groups—and what he's keeping an eye out for next year. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
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    13 mins
  • Taxpayers 'Gamble' by Committing Fraud, Even With Diminished IRS

    Taxpayers 'Gamble' by Committing Fraud, Even With Diminished IRS
    Dec 3 2025
    Anyone thinking about pushing the boundaries of tax law should remember that there's no federal statute of limitations on prosecuting fraud, even with weakened IRS enforcement, said Carolyn Schenck, who spent 20 years at the agency primarily combating tax evasion. "If people think that a current administration or a past administration might go soft on tax fraud, that's still an awfully big gamble," said Schenck, who's now at Caplin & Drysdale. "And I know that that's not one I personally would want to take." The IRS is coming off a tumultuous year with deep staffing cuts from the Trump administration's efforts to downsize the federal government and a parade of new commissioners. But increasing IRS staff and resources would be one of the best ways the government could combat fraud and collect more of the money it's owed, Schenck said. On this episode of Talking Tax, Schenck sat down with Bloomberg Tax reporter Erin Schilling to discuss what Trump administration workforce cuts mean for IRS enforcement and how the agency could improve its efforts to go after illegal tax shelters, even with a diminished staff. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
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    15 mins
  • Cross-Border Tax Fraud an Old Story, Roman Scroll Shows (Rerun)

    Cross-Border Tax Fraud an Old Story, Roman Scroll Shows (Rerun)
    Nov 26 2025
    For the holidays, we serve up an encore presentation of a Talking Tax podcast that shows cross-border tax fraud has been around a long time. When researchers studied a previously mislabeled scroll, they discovered detailed attorney notes for a case against taxpayers accused of using forged documents and sham transactions between the Roman provinces of Judaea and Arabia to escape taxes on their assets. The assets in question were enslaved people. The potential punishments included distinctly unmodern measures. Anna Dolganov of the Austrian Academy of Sciences talked with reporter Caleb Harshberger about how scholars made the discovery, details of the scheme, and what they’re hoping to uncover next as they continue their research. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
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    15 mins
  • What Comes Next for the IRS and Tax After the Long Shutdown

    What Comes Next for the IRS and Tax After the Long Shutdown
    Nov 19 2025
    Congress is back after ending the longest shutdown in US history. But the bipartisan accord left funding for the IRS and Treasury Department ending in less than three months and the fate of the enhanced premium tax credits at the center of the crisis still unresolved. On this episode of Talking Tax, Bloomberg Tax Congress reporter Zach C. Cohen and Bloomberg Government health policy reporter Erin Durkin discuss next steps for appropriating funds for the IRS and Treasury after current funding runs dry Jan. 30, and potential legislative solutions to rising health-care premiums. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
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    15 mins
  • Mamdani's NYC Tax Agenda Prompts Advisers to Caution Patience

    Mamdani's NYC Tax Agenda Prompts Advisers to Caution Patience
    Nov 13 2025
    New York City Mayor-elect Zohran Mamdani ran on an expansive affordability agenda that would be paid for by higher taxes on corporations and wealthy individuals. The democratic socialist's vision will be tough to realize, though, because any tax hikes would have to be approved by the New York State legislature and tax hike-averse Gov. Kathy Hochul (D). Local tax practitioners are emphasizing this political reality to worried clients who called and emailed in a hurry after Mandani won the Nov. 4 mayoral contest. “There’s been kind of some demystifying as to how can or how will the mayor be able to make these ideas or proposals law," Jeremy Gove, a state and local tax counsel at Eversheds Sutherland, tells Bloomberg Tax editor Benjamin Freed on this week's episode of the Talking Tax podcast. "Explaining this to taxpayers is what we’ve been tackling over the past week or so.” Gove says that while higher taxes could compel some New York companies and wealthy individuals to decamp for lower-tax states, there's also a "wait and see" sentiment prevailing. Taxpayers might even welcome some proposals from Mamdani, such as hiring more auditors to clear out the Department of Finance's hefty case backlog, he says. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
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    12 mins