The Essential Tax Podcast

Mishkin Santa, The Wolf Group

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CHAQUE SEMAINE

In each episode of The Essential Tax Podcast, Mishkin Santa takes on the complex world of tax, guiding you through a range of tax topics in a way that cuts through the jargon, acronyms, and complexities that make your eyes glaze over, so that you can understand the latest developments and how they relate to you.

-4 J

From Green to Gold to Platinum Cards: Immigration Attorney Jason Levy’s Insights

The Essential Tax Podcast with Mishkin Santa, Season 2, Episode 12 In this episode of The Essential Tax Podcast, Mishkin Santa speaks with Jason Levy, JD, Counsel at Grossman, Young & Hammond. Jason has been practicing law in the United States for over 28 years. Previously, Jason served as Senior Attorney with the Office of the General Counsel, Immigration Law Division at the U.S. Department of Homeland Security (DHS). While at DHS, Jason advised policy, operational, and legal leadership on a wide array of immigration-related rulemakings and policies instituted by DHS and its component agencies (USCIS, CBP, and ICE), with a primary focus on employment-based immigration policies. Tune in for these key takeaways: A brief history of the development of immigration law in the US Ways to obtain permanent residency with the USWhen the US government might change or update the current US Immigration statutes, and when they won’tIn-depth discussion of different types of US Visas, how to obtain each one, and speculation of how the criteria may change in the futureDiscussion about the status of the US government’s Gold Card and Platinum Card initiatives and how they might affect US immigration law and tax residencyCommon misconceptions and certain facts about how a person might inadvertently surrender their US Green Card and options for those individuals to maintain or preemptively protect their LPR status Learn more about Jason Levy: Visit the Resources page on Grossman Young & Hammond’s website: https://www.grossmanyoung.com/resources/View Jason Levy’s profile on Grossman Young & Hammond’s website: https://www.grossmanyoung.com/attorneys/jason-levy/Connect with Jason Levy on LinkedIn: https://www.linkedin.com/in/jason-levy-5776a41/Follow Grossman, Young & Hammond on LinkedIn: https://www.linkedin.com/company/grossmanyoung/Visit Grossman, Young & Hammond’s YouTube Channel: https://www.youtube.com/@grossmanyounghammondllc73Follow Grossman, Young & Hammond on Facebook: https://www.facebook.com/grossmanyoung/ Further Resources: US DOJ Executive Office of Immigration Review - https://www.justice.gov/eoirUS DOJ Matter of Lok (1981) - https://www.justice.gov/sites/default/files/eoir/legacy/2012/08/14/2878.pdfMatter of Wong (1977) - https://www.justice.gov/sites/default/files/eoir/legacy/2012/08/17/2549.pdfGold Card Website - https://trumpcard.gov/Matter of Kane (1975) - https://www.justice.gov/sites/default/files/eoir/legacy/2012/08/17/2371.pdf *********************************** About The Essential Tax Podcast: In each episode of The Essential Tax Podcast, Mishkin Santa takes on the complex world of tax — all the jargon, acronyms, and stuff that makes your eyes glaze over, and explains it in an impactful way to understand the complex and unknown areas. Watch or listen to more episodes of The Essential Tax Podcast: YouTube: https://www.youtube.com/@TheWolfGroupPCApple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf Connect and learn more from your host, Mishkin Santa: Connect with Mishkin on LinkedIn: https://www.linkedin.com/in/msantaFollow The Wolf Group on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pcRead Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa

1 h 18 min
9 OCT.

2025 Transfer Pricing Update with Nghi Huynh

The Essential Tax Podcast with Mishkin Santa, Season 2, Episode 11 In this episode of The Essential Tax Podcast, Mishkin Santa speaks with Nghi Huynh, Transfer Pricing Partner-in-Charge, Armanino Advisory LLC. Nghi is a proven tax professional with over 20 years of experience in transfer pricing, research, audit, and tax planning projects within Big 4 public accounting firms. Tune in for these key takeaways: An overview of Transfer Pricing models, planning, and industries that commonly utilize this methodWhat Transfer Pricing might look like for a small startup company entering into international markets that include mid-size to large competitorsWhen and how to enlist assistance with transfer pricing beyond tangible goods (services, IP, cost-sharing, financing arrangements)Situations that might call for Advance Pricing Agreements or Mutual Agreement ProceduresAn overview of typical Transfer Pricing documentation, when to refresh, and how best to maintain long-termDetails about common intercompany funding pitfalls when multinational enterprises establish and expand their foreign operationsA discussion of a few of the most efficient ways for parent companies to fund foreign subsidiaries (loans, capitalization, short-term AR/AP)Updates on the current state of transfer pricing litigation with the IRS and high-risk jurisdictions for audits and adjustments Learn more about Nghi Huynh: Visit the Transfer Pricing page on Armanino’s website: https://lnkd.in/gZHF5hjYView Armanino’s website: https://www.armanino.com/Connect with Nghi Huynh on LinkedIn: linkedin.com/in/nghi-huynhCheck out Armanino’s most recent Transfer Pricing newsletter: https://www.linkedin.com/posts/tax-armanino_armanino-tariff-advisory-ugcPost-7371204268365737984-xq5Z/?utm_source=social_share_send&utm_medium=member_desktop_web&rcm=ACoAAADbAhkB5xgWo_NM0eh5PpgcFdl7gNb6C_AFollow Armanino on LinkedIn: https://www.linkedin.com/company/armanino/Visit Armanino’s YouTube Channel: https://www.youtube.com/c/armaninoFollow Armanino on Facebook: https://www.facebook.com/Armanino.HQ/ *********************************** About The Essential Tax Podcast: In each episode of The Essential Tax Podcast, Mishkin Santa takes on the complex world of tax — all the jargon, acronyms, and stuff that makes your eyes glaze over, and explains it in an impactful way to understand the complex and unknown areas. Watch or listen to more episodes of The Essential Tax Podcast: YouTube: https://www.youtube.com/@TheWolfGroupPCApple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf Connect and learn more from your host, Mishkin Santa: Connect with Mishkin on LinkedIn: https://www.linkedin.com/in/msantaFollow The Wolf Group on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pcRead Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa

54 min
30 SEPT.

Tax Practitioners Social Media/Influencer Guidance, Charitable Contribution Update, & IRS Refunds

The Essential Tax Podcast with Mishkin Santa, Season 2, Episode 10 In this episode of The Essential Tax Podcast, your host, Mishkin Santa, dives into some hot tax topics for #InternationalPodcastDay. Tune in for these key takeaways: Social media & Influencer guidance for tax practitioners and relevant case law.When a tax practitioner might be considered culpable for advice offered on social media.Some of the dangers of a one-size-fits-all approach to professional tax advice.The importance of a disclaimer and when offering tax advice on social media.An outline of the One Big Beautiful Bill Act’s changes to IRS rules for charitable contributions and why this might be important for your own personal tax planning.A brief guided tour of the brand-new IRS Schedule 1A that pertains to certain tax deductions.An upcoming change at the IRS, stemming from an Executive Order by the US President, that will change the way refunds & paper checks are accepted and/or processed. Further Resources: 2025 “Draft” Schedule 1-A: https://www.irs.gov/pub/irs-dft/f1040s1a--dft.pdfExecutive Order – Modernizing Payments to and from America’s Bank Account: https://www.whitehouse.gov/presidential-actions/2025/03/modernizing-payments-to-and-from-americas-bank-account/TWG Blog Post - https://thewolfgroup.com/blog/the-irs-will-stop-issuing-refunds-via-paper-check-in-september-2025/ *********************************** About The Essential Tax Podcast: In each episode of The Essential Tax Podcast, Mishkin Santa takes on the complex world of tax — all the jargon, acronyms, and stuff that makes your eyes glaze over, and explains it in an impactful way to understand the complex and unknown areas. Watch or listen to more episodes of The Essential Tax Podcast: YouTube: https://www.youtube.com/@TheWolfGroupPCApple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf Connect and learn more from your host, Mishkin Santa: Connect with Mishkin on LinkedIn: https://www.linkedin.com/in/msantaFollow The Wolf Group on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pcRead Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa

18 min
29 SEPT. · BONUS

New! The Gold Card – Don’t Leave Home Without It!

Tune in to this mini episode of The Essential Tax Podcast for practical tips and updates on a timely topic in the international tax realm. Your host, Mishkin Santa, will briefly guide you through the most up-to-date information on this hot tax topic as well as provide his invaluable analysis and expert recommendations. About The Essential Tax Podcast: In each episode of The Essential Tax Podcast, Mishkin Santa takes on the complex world of tax — all the jargon, acronyms, and stuff that makes your eyes glaze over, and explains it in an impactful way to understand the complex and unknown areas. Watch or listen to more episodes of The Essential Tax Podcast: YouTube: https://www.youtube.com/@TheWolfGroupPC Apple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944 Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf Connect and learn more from your host, Mishkin Santa: Connect with Mishkin on LinkedIn: https://www.linkedin.com/in/msanta Follow The Wolf Group on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa

10 min
27 AOÛT

2025 FinCEN Form 114 (FBAR) Update and Latest News

The Essential Tax Podcast with Mishkin Santa, Season 2, Episode 9 In this episode of The Essential Tax Podcast, Mishkin Santa discusses recent news items related to FinCEN Form 114 (FBAR) requirements, and how they will affect US and international tax reporting. Tune in for these key takeaways: A brief history of the FBAR’s origins in the Bank Secrecy Act of 1970.A summary of which taxpayers need file an FBAR and an explanation of the aggregate reporting threshold that triggers the requirement.Tips for recordkeeping and due diligence that can aid in making ongoing FBAR reporting and potential audit defense more manageable.A discussion of recent court cases that have affected judicial treatment of FBAR disputes and penalty assessments.An overview of current penalties for noncompliance with FBAR filing requirements. Further Resources: Bank Secrecy Act of 1970 - https://www.fincen.gov/resources/statutes-and-regulations/bank-secrecy-actIRS FBAR Practice Unit - https://www.irs.gov/pub/fatca/int_practice_units/fincen-form114-fbar.pdf IRS Schedule B - https://www.irs.gov/forms-pubs/about-schedule-b-form-1040 United States v. Timberly E. Hughes - https://law.justia.com/cases/federal/appellate-courts/ca9/23-15712/23-15712-2024-08-21.htmlIRM 4.26.16.4.4.1 - https://www.irs.gov/irm/part4/irm_04-026-016 United States v. Saydam - https://dockets.justia.com/docket/california/candce/4:2022cv07371/404157 United States v. Rohrbasser - https://dockets.justia.com/docket/connecticut/ctdce/3:2024cv00959/159875United States v. Rotta - https://www.justice.gov/opa/pr/wealthy-miami-man-pleads-guilty-decades-long-scheme-defraud-irsUnited States v. Leeds - https://law.justia.com/cases/federal/district-courts/idaho/iddce/1:2022cv00379/50692/36/United States v. Gernot John Noell - https://www.courtlistener.com/docket/65386409/united-states-v-noell/United States v. Stephen M. Kerr - https://www.courtlistener.com/docket/16355120/united-states-v-kerr/ United States v. Sagoo - https://dockets.justia.com/docket/texas/txndce/4:2024cv01159/397369 Kurotaki v. United States - https://law.justia.com/cases/federal/district-courts/hawaii/hidce/1:2022cv00063/157629/50/ Bittner v. United States - https://www.supremecourt.gov/opinions/22pdf/21-1195_h3ci.pdfIRS Memo SBSE-04-0723-0034 - https://www.irs.gov/pub/foia/ig/sbse/sbse-04-0723-0034-redacted.pdf2025 FBAR Penalty Adjustment Table - https://www.federalregister.gov/documents/2025/01/17/2025-01374/financial-crimes-enforcement-network-inflation-adjustment-of-civil-monetary-penalties *********************************** About The Essential Tax Podcast: In each episode of The Essential Tax Podcast, Mishkin Santa takes on the complex world of tax — all the jargon, acronyms, and stuff that makes your eyes glaze over, and explains it in an impactful way to understand the complex and unknown areas. Watch or listen to more episodes of The Essential Tax Podcast: * YouTube: https://www.youtube.com/@TheWolfGroupPC Apple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944 Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf Connect and learn more from your host, Mishkin Santa: Connect with Mishkin on LinkedIn: https://www.linkedin.com/in/msanta Follow The Wolf Group on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc Read Mishkin’s bio on The Wolf Group’s website: https://thewolfgroup.com/our-people/mishkin-santa

25 min
14 AOÛT · BONUS

Substantiation for Conversion of Personal Residence to Rental

Title: Substantiation for Conversion of Personal Residence to Rental Property Show Notes: Smith v. Commissioner, T.C. Memo 2025-24 (March 24, 2025)Treasury Regulation 1.167(g)-1: https://www.law.cornell.edu/cfr/text/26/1.46-3 About The Essential Tax Podcast: In each episode of The Essential Tax Podcast, MishkinSanta takes on the complex world of tax — all the jargon, acronyms, and stuffthat makes your eyes glaze over, and explains it in an impactful way tounderstand the complex and unknown areas. Watch or listen to more episodes of The Essential TaxPodcast: * YouTube: https://www.youtube.com/@TheWolfGroupPC * Apple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944 * Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf Connect and learn more from your host, Mishkin Santa: * Connect withMishkin on LinkedIn: https://www.linkedin.com/in/msanta * Follow The WolfGroup on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc * Read Mishkin’s bio on The Wolf Group’swebsite: https://thewolfgroup.com/our-people/mishkin-santa

5 min
14 AOÛT · BONUS

Placed in Service Rules Update

Title: Placed in Service Rules Update Show Notes: Lentine v. Commissioner, T.C. Docket No. 12443-21 (March 25, 2025)Treasury Regulation 1.167(a)-10: https://www.law.cornell.edu/cfr/text/26/1.167(a)-10 Treasury Regulation 1.46-3: https://www.law.cornell.edu/cfr/text/26/1.46-3About The Essential Tax Podcast: In each episode of The Essential Tax Podcast, MishkinSanta takes on the complex world of tax — all the jargon, acronyms, and stuffthat makes your eyes glaze over, and explains it in an impactful way tounderstand the complex and unknown areas. Watch or listen to more episodes of The Essential TaxPodcast: * YouTube: https://www.youtube.com/@TheWolfGroupPC * Apple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944 * Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf Connect and learn more from your host, Mishkin Santa: * Connect withMishkin on LinkedIn: https://www.linkedin.com/in/msanta * Follow The WolfGroup on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc * Read Mishkin’s bio on The Wolf Group’swebsite: https://thewolfgroup.com/our-people/mishkin-santa

6 min
14 AOÛT · BONUS

Foreign Rental Property and Qualified Business Reporting

Title: Foreign Rental Property and Qualified Business Reporting Show notes: IRS: Form 8858: https://www.irs.gov/pub/irs-pdf/f8858.pdf IRC 168: https://www.law.cornell.edu/uscode/text/26/168 Treasury Regulation 1.989(a)-1: https://www.law.cornell.edu/cfr/text/26/1.989(a)-1About The Essential Tax Podcast: In each episode of The Essential Tax Podcast, MishkinSanta takes on the complex world of tax — all the jargon, acronyms, and stuffthat makes your eyes glaze over, and explains it in an impactful way tounderstand the complex and unknown areas. Watch or listen to more episodes of The Essential TaxPodcast: * YouTube: https://www.youtube.com/@TheWolfGroupPC * Apple: https://podcasts.apple.com/us/podcast/the-essential-tax-podcast/id1754660944 * Spotify: https://open.spotify.com/show/2beZfOpwfBlBgWHlNelAOf Connect and learn more from your host, Mishkin Santa: * Connect withMishkin on LinkedIn: https://www.linkedin.com/in/msanta * Follow The WolfGroup on LinkedIn: https://www.linkedin.com/company/the-wolf-group-pc * Read Mishkin’s bio on The Wolf Group’swebsite: https://thewolfgroup.com/our-people/mishkin-santa

7 min

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In each episode of The Essential Tax Podcast, Mishkin Santa takes on the complex world of tax, guiding you through a range of tax topics in a way that cuts through the jargon, acronyms, and complexities that make your eyes glaze over, so that you can understand the latest developments and how they relate to you.

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Mishkin Santa, The Wolf Group
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2024 - 2025
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51
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