20 episodes

tax break is a podcast about tax law, brought to you by lawyers at Miller & Chevalier. 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. We’re only going to select topics that we think are interesting – the shiny objects that catch our attention.

tax break Miller & Chevalier

    • News
    • 5.0 • 7 Ratings

tax break is a podcast about tax law, brought to you by lawyers at Miller & Chevalier. 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. We’re only going to select topics that we think are interesting – the shiny objects that catch our attention.

    Liberty Global: The First Challenge to the 245A Regs | tax break Episode 19

    Liberty Global: The First Challenge to the 245A Regs | tax break Episode 19

    With the action by Liberty Global in November of last year, we have the first challenge to the validity of the Temporary Regulations under section 245A. We discuss those regulations and some of the arguments we will see in that case. 


    Topics discussed:
    1. The section 245A deduction, the “GILTI donut hole,” and what the Temporary Regulations do to address that “donut hole”
    2. Liberty Global’s complaint
    3. Assessment of Liberty Global’s arguments that the Temporary Regulations are invalid


    *********


    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.

    • 45 min
    American Jobs Plan Calls for Major Changes to the International Tax Landscape | tax break Episode 18

    American Jobs Plan Calls for Major Changes to the International Tax Landscape | tax break Episode 18

    Loren and Steve will discuss the tax proposals included in the American Jobs Plan, which are meant to fund large infrastructure investments the Biden administration plans to make.


    Topics addressed will include proposed modifications to the GILTI, BEAT, and FDII regimes, as well as new provisions like the minimum tax on book income and a carrot/stick approach to addressing U.S. multinationals’ onshoring and offshoring activities.


    *********


    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.

    • 40 min
    Insights on Transfer Pricing Valuation | tax break Episode 17

    Insights on Transfer Pricing Valuation | tax break Episode 17

    In this episode, Loren and Steve speak with Mike Cragg from The Brattle Group about economics and transfer pricing valuations. 


    Over time, the modes of economic valuation for transfer pricing purposes have become predictable and sometimes rote. Are there other ways to skin the proverbial cat? On this episode, we discuss some possible novel approaches with Mike Cragg, an experienced economist and the Principal & Chairman at The Brattle Group. In particular, we’ll discuss the role that insights from antitrust economics and notions of minority discounts might play in transfer pricing valuations. 


    *********


    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.

    • 36 min
    Breaking Down Facebook’s Litigation in the Tax Court, Part 2 | tax break Episode 16

    Breaking Down Facebook’s Litigation in the Tax Court, Part 2 | tax break Episode 16

    Facebook is embroiled in a transfer pricing dispute with the IRS in Tax Court. This week on tax break, Steve and Loren conclude their discussion of what's at issue in the case. Listen to part 1 of the discussion in Episode 14.


    Topics discussed:


    Basics of the dispute

    Whether aggregation of the three disputed royalties is reliable here

    Pricing the Platform Contribution Transaction royalty

    Challenge to validity of the -7T regulations

    Nature of the User Base and associated royalty

    Subsequent legal changes and changes to structure


    *********


    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.

    • 36 min
    The 2021 Tax Policy Forecast Survey | tax break Episode 15

    The 2021 Tax Policy Forecast Survey | tax break Episode 15

    This week, Steve and Loren discuss the results of the joint Miller & Chevalier and National Foreign Trade Council 2021 Tax Policy Forecast Survey with Miller & Chevalier Tax Member Marc Gerson.


    View the survey here: https://bit.ly/taxpolicy2021 


    Topics discussed:


    Genesis of the survey

    Design of its questions

    Expectations for results

    Surprises in those results

    Other observations on the results


    Thanks to our guest, Marc Gerson: https://www.millerchevalier.com/professional/marc-j-gerson 


    ****


    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.

    • 27 min
    Breaking Down Facebook's Litigation in the Tax Court, Part 1 | tax break Episode 14

    Breaking Down Facebook's Litigation in the Tax Court, Part 1 | tax break Episode 14

    Facebook is embroiled in a transfer pricing dispute with the IRS in Tax Court. This week on tax break, Steve and Loren discuss what's at issue in the case.


    Topics discussed:


    Basics of the dispute

    Whether aggregation of the three disputed royalties is reliable here

    Pricing the Platform Contribution Transaction royalty

    Challenge to validity of the -7T regulations

    Nature of the User Base and associated royalty

    Subsequent legal changes and changes to structure


    *********


    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.

    • 27 min

Customer Reviews

5.0 out of 5
7 Ratings

7 Ratings

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