tax brea‪k‬ Miller & Chevalier

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 Ponds are joined by their colleagues Jorge Castro and Marc Gerson to discuss:
Contents of the Consolidated Appropriations Act, 2021
New Composition of Finance and Ways & Means
What Can Be Accomplished with Reconciliation?
Possible Content of Reconciliation Vehicles
Business Tax Proposals
Thanks to our guests:
Jorge Castro: https://www.millerchevalier.com/professional/jorge-e-castro Marc Gerson: https://www.millerchevalier.com/professional/marc-j-gerson
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Questions? Contact us at podcasts@milchev.com.
tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you’ll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts.

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 jurisdictional nexus standard, as well as the implications of these modifications.
Thanks to our guest, Rocco Femia: https://www.millerchevalier.com/professional/rocco-v-femia
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Questions? Contact us at podcasts@milchev.com.
tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you’ll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts.

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, where she worked on the 2017 tax law, and what she learned along the way. Loren is interviewed by Nana Ama Sarfo, who recently profiled her in Tax Notes' For the Love of Tax series.  You can check out that profile here: http://bit.ly/PondsProfile 
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Questions? Contact us at podcasts@milchev.com.
tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you'll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts.

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 might mean for transfer-pricing valuation.
We'll speak about the endeavor of transfer pricing valuation as it relates to worldwide effective-tax-rate management, how the last round of OECD initiatives (under BEPS) changed the valuation landscape, and what might happen to that landscape with the two developing OECD pillars (the first of which contemplates some possible formulary apportionment among markets, the second of which contemplates a minimum tax that may be assessed on the basis of book financials). 
Thanks to our guest, Simon Webber: https://www.duffandphelps.com/our-team/simon-webber
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Questions? Contact us at podcasts@milchev.com.
tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you'll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts.

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-Elect Joe Biden. Jorge served on the Obama-Biden Transition Team in 2008 and provides perspective about how the incoming Biden administration is currently assessing these issues. We discuss significant general corporate changes, international tax changes, other domestic possibilities, and areas for bipartisan agreement.
Thanks to our guest, Jorge Castro: https://www.millerchevalier.com/professional/jorge-e-castro 
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Questions? Contact us at podcasts@milchev.com.
tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you'll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts.

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 the business that have been affected by FDII, and policy discussion underscoring the importance of the provision now and going forward:
Practical considerations (supply chain considerations, corollary to GILTI, impact to M&A transactions)
Policy considerations (Biden tax proposals – Made in America, R&D innovation and incentivization, impact of impending R&D amortization provision)
Thanks to our guest, Sharon Heck: https://www.linkedin.com/in/sharonlheck/ 
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Questions? Contact us at podcasts@milchev.com.
tax break is not intended and cannot be relied on as legal advice; the content only reflects the thoughts and opinions of its hosts.
tax break is a podcast about tax law, brought to you by Miller & Chevalier and hosted by Steve Dixon and Loren Ponds. We'll provide you with perspective on select tax issues that will go deeper than what the tax press covers, but not so deep that you'll have to pull out your regulations or read treatises to follow along. The aim of tax break is to focus only on the tax law issues that we find interesting. Subscribe to tax break wherever you get your podcasts.