Talking Tax Bloomberg Industry Group

African countries face several challenges in negotiating the global tax deal involving more than 140 countries at the Organization for Economic Cooperation and Development.
The agreement includes reallocation of the residual profits of large multinational companies to market jurisdictions, known as Pillar One, and a 15% global minimum tax, known as Pillar Two.
On this week’s episode of Talking Tax, Bloomberg Tax senior reporter Danish Mehboob speaks with Logan Wort, executive secretary at the African Tax Administration Forum, about why developing countries feel they don't have a seat at the table for these negotiations and why some would prefer to have the project play out at the United Nations rather than the OECD.
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Marita Sciarrotta, the new acting director of New Jersey's Division of Taxation, will have a busy year ahead as she settles into the role.
Sciarrotta, who spent 40 years in the tax division before taking over as acting director in September, said in an interview that she wants to modernize the state's property tax relief programs—an endeavor that likely will require legislation to make needed changes. She also plans to increase hiring as state revenue agencies across the nation grapple with a growing number of vacancies that can impede their abilities to provide financial oversight.
On this episode of Talking Tax, reporter Danielle Muoio Dunn spoke with Sciarrotta about her plans as the division takes on lawmakers’ overhaul of New Jersey’s corporate tax system and the creation of StayNJ, a property tax relief program for seniors. Sciarrotta also discussed her long tenure in the division and the sexism she's faced over the years.
"There are some people that kind of tend to be siloed off and one of the things I found to be most advantageous in my career is that I get like a morbid curiosity and I will ask about anything to anyone and stick my nose in a lot of different places," Sciarrotta said.
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(Note: This episode originally aired June 1, 2023)
What does it mean to be a good tax leader, as an in-house tax professional or as a tax adviser who wants to make the tax functions of your clients better? How do you build a great team?
Bloomberg Tax Insights editor Rebecca Baker sat down with Jared Dunkin, the vice president of tax and senior tax counsel at FTI Consulting, and Dunkin’s mentor and former boss, Todd Davis, the executive vice president and senior tax counsel for Warner Bros. Discovery, to find some answers to these questions.
Dunkin and Davis discuss how to handle the ambiguity of tax when corporate executives—their bosses—demand certainty, how to wage the war for talent, and how to set priorities for their tax teams, particularly when it comes to cross-border tax work.
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For more than a year, a group of wealth management advisers met regularly to devise strategies to defend their wealthy clients' keeping their riches in individual retirement arrangements based in Malta.
The pension plans—which emerged out of a loophole in a 2011 tax treaty between the US and the Mediterranean island nation widely seen as a tax haven—involved a cottage industry of advisers, accountants, and attorneys to facilitate transactions that allowed cash, business interests, and several types of income to go untaxed.
The plans were added to IRS's "Dirty Dozen" list of dubious tax schemes in July 2021. But participants in the participants' monthly Zoom meetings felt "the IRS was too simple, too lazy, or too stupid to figure out what we were doing," according to one wealth adviser who attended them. That changed in June, when the IRS served hundreds of criminal summonses on taxpayers and Malta pension plan promoters. While no charges have been filed yet, IRS Commissioner Danny Werfel has been vocal about cracking down on abusive tax schemes, especially now that his agency is infused with billions in new funding from last year's tax-and-climate law.
In this week's episode of Talking Tax, host David Schultz talks to Bloomberg Tax reporter Michael J. Bologna about his story digging into the wealth advisers' meetings, how these Malta plans were marketed to high-net-worth individuals, and what's next for the IRS investigation.
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The clock is ticking on Gov. Kathy Hochul (D) to take action on legislation that would make New York the first state to publicly list the owners behind limited liability companies.
The bill, A3484A, would require LLCs to disclose their beneficial owners and other identifying information, such as their business street address. Those who fail to comply for more than two years would be shown as “delinquent” on state records and subject to a $250 penalty. Entities with “significant privacy interests” could apply for a waiver to not appear in the state registry.
On this episode of Talking Tax, Bloomberg Tax spoke with state Sen. Brad Hoylman-Sigal, the Manhattan Democrat who sponsored the bill, and Chelsea Lemon, director of government affairs for the Business Council of New York, which opposes the legislation.
"The LLC Transparency Act doesn't minimize or alter the legal structure or protections of LLCs, but it provides necessary transparency for the public's benefit, as well as our law enforcement," Hoylman-Sigal said.
Other proponents, including state Attorney General Letitia James and Comptroller Thomas DiNapoli, have said the opaque structure of LLCs allow corrupt actors to hide their financial dealings and contribute to issues like tax evasion and money laundering. Opponents, such as real estate groups, have raised privacy concerns with it and said it will hurt the state's economic competitiveness.
A spokesperson for Hochul said she's "reviewing the legislation." She has until Dec. 31 to act on the bill. 
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It isn't every day that a dispute over a $14,729 tax bill gets every corner of the tax world paying attention—but the potential ramifications of the dispute now before the Supreme Court go far beyond that.
The court will hear oral arguments next month in Moore v. United States, in which Charles and Kathleen Moore, a retired couple from Washington state, are arguing that the “mandatory repatriation tax” should be declared unconstitutional. That tax, enacted as part of the 2017 tax-overhaul law, imposed a one-time levy on accumulated foreign corporate profits when the US changed its tax system so as to tax foreign profits going forward. It also led to the Moores’ $14,729 tax bill, which they had to pay on earnings of an Indian machine-tool company in which they’d invested, even though the earnings weren’t distributed to them.
If the high court rules in the Moores’ favor, it could lead to hundreds of billions of dollars in refunds to giant multinational companies that paid the mandatory repatriation tax. Some observers think it could also play havoc with other taxes on foreign income, partnership taxes, and other forms of tax that are similarly based on undistributed income.
The Moores and their supporters distinguish the mandatory repatriation tax from other provisions, and contend it can be struck down without disrupting the rest of the tax code. The US Chamber of Commerce said in a brief supporting the Moores that such concerns were "badly overblown."
Bloomberg Tax senior reporter Michael Rapoport spoke about the Moore case with Reuven Avi-Yonah, a law professor at the University of Michigan, who specializes in corporate and international taxation. Avi-Yonah filed a friend-of-the-court brief with two other law professors last month urging the Supreme Court to reject the Moores’ challenge.
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