Tax Notes Talk

Tax Notes chief correspondent Stephanie Soong discusses the OECD’s recent pillar 2 side-by-side package deal and how countries are adapting to the new landscape. 
For related tax news, read the following in Tax Notes:
U.S. Focusing on OECD Guidance for Pillar 2 Side-by-Side Package
Hungary Expands Global Minimum Tax Registration Form
U.S. Treasury Officials Declare Death of OECD Pillar 1

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Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Rozeta Atlas of HubSync discusses the IRS’s plan to overhaul its legacy IT systems and what a modernized agency may mean for practitioners.
For related tax news, read the following in Tax Notes:
Palantir Contracts Under Scrutiny Amid IRS Tax Data Controversy
IRS Adopts Generative Artificial Intelligence Policy
IRS No-Paper Initiative Jammed by Staffing Issues, Watchdog Says

***
Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Professors Jeremy Bearer-Friend and Sarah Polcz discuss their recent paper, “Sharing the Algorithm: The Tax Solution to Generative AI,” which outlines their proposal for taxing generative AI companies.
For more, read Bearer-Friend and Polcz's article.
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Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Professor Andrea Campbell, author of Taxation and Resentment: Race, Party, and Class in American Tax Attitudes, discusses why Americans' beliefs about taxes often don’t align with the specific tax policies they support.
For more on Taxation and Resentment, you can read Joseph Thorndike's book review here: "ANALYSIS: Why Do Americans Ignore Their Self-Interest When It Comes to Taxes?"
If you're interested in hearing more about Andrew Kahrl's research on the property tax, check out our episode, "Tax or Theft? Examining the History of the Property Tax." 
***
Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.

Damien Martin and Tony Nitti of EY discuss the second three of their top six tax cases of 2025, focusing on what qualifies as a deduction in Savage v. Commissioner, Kelly v. Commissioner, and Weston v. Commissioner.
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Credits
Host: David D. Stewart
Executive Producers: Jeanne Rauch-Zender, Paige Jones
Producers: Jordan Parrish, Peyton Rhodes
Audio Engineers: Jordan Parrish, Peyton Rhodes
This episode is sponsored by the University of California Irvine School of Law Graduate Tax Program. For more information, visit law.uci.edu/gradtax.