Épisodes

  • US Global Tax Carve-Out Beats Retaliation, Siemens Exec Says

    US Global Tax Carve-Out Beats Retaliation, Siemens Exec Says
    Jan 21 2026
    A global minimum tax deal that exempts American companies from key provisions is a better outcome for European business than the alternative of US retaliatory taxes, a top German tax executive says. The package agreed to this month by more than 145 countries at the Organization for Economic Cooperation and Development headed off a threat of steep US taxes on foreign companies if global concessions weren't made. In this episode of Talking Tax, Christian Kaeser, global head of tax at Siemens AG, told Bloomberg Tax reporter Ryan Hogg that some of his European counterparts regarded the deal as “lopsided” but welcomed new permanent safe harbors that were created with input from Business at OECD, known as BIAC. Kaeser is co-chair of BIAC's tax committee. "I'm pretty happy with the outcome," he said. Competitive disparities created by the deal can be remedied by simplification of the EU’s own rules, including scrapping of the bloc’s controlled foreign companies anti-tax avoidance regime, he said. As for Pillar One, the other main part of a 2021 OECD-led tax agreement, Kaeser saw little hope. Further talks on the pillar, which would reallocate taxing rights to countries where big companies make their profits, have stalled for years. It "should be called Pillar Zed, zed for zombie," he said. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
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    11 min
  • OECD Deal Success Hinges on Implementation, Rep. Estes Says

    OECD Deal Success Hinges on Implementation, Rep. Estes Says
    Jan 14 2026
    Republicans on Capitol Hill are keenly watching how other countries implement a long-sought OECD agreement that exempts US companies from parts of the global minimum tax framework. Rep. Ron Estes (R-Kan.), a member of the tax-writing House Ways and Means Committee, hasn't ruled out resurrecting legislation imposing retaliatory taxes on firms from nations that slow-walk codifying the deal. The deal was reached earlier this month after the Trump administration demanded a carve-out for American companies and for the US tax system to work alongside the global minimum tax framework without interference. Estes sat down with Bloomberg Tax Congress reporter Zach C. Cohen in his Capitol Hill office to talk about the importance of the agreement to American businesses and how he will "trust, but verify" other countries' tax code changes, especially if they pursue the same kind of exemption Washington just secured. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
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    16 min
  • Making Sense of the Global Tax Carve-Out for US Companies

    Making Sense of the Global Tax Carve-Out for US Companies
    Jan 7 2026
    The OECD just published the parameters of a deal that would exempt US companies from two key enforcement rules in the global minimum tax framework. The deal, which spans 88 pages in the form of administrative guidance, includes a slew of safe harbor rules that address everything from how US companies can get the exemption to more advantageous treatment of substance-based tax incentives like the US R&D credit. It includes a permanent, simplified global minimum tax calculation. Other countries would be able to obtain carve-outs like the ones obtained by the US and its multinational companies—if they meet certain criteria. This week on Talking Tax, reporters Lauren Vella and Somesh Jha discuss why the deal and the timing of its release is important, what it means for multinational businesses, how key US lawmakers reacted, and what the deal means for the efficacy of the global minimum tax going forward. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
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    16 min
  • How Transfer Pricing Offers a Fix for Student Athletes (Rerun)

    How Transfer Pricing Offers a Fix for Student Athletes (Rerun)
    Dec 31 2025
    We're off for the New Year holiday, so we're serving up an encore presentation of a Talking Tax podcast about challenges with paying student athletes. Ever since student athletes gained the right to be compensated for use of their image in advertisements and merchandise sales, the money has flooded in, but so have some problems. The athletes can now be compensated for their name, image, and likeness—or NIL—but schools still can’t directly pay them for playing. Instead, athletes can receive compensation when merchandise with their name or number is sold, or for showing up in advertisements or social media posts for businesses. But the line between legitimate NIL and illegitimate pay-for-play can get blurry. On this episode of Talking Tax, University of Kentucky professor Stephen Lusch talks with reporter Caleb Harshberger about how transfer pricing and tax law concepts can show whether the deals are done at reasonable prices that really reflect the value the student brings. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
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    14 min
  • PwC Coaches New Tax Associates on AI Tools in US Training Effort

    PwC Coaches New Tax Associates on AI Tools in US Training Effort
    Dec 23 2025
    PwC's new training program aims to give early-career recruits hands-on experience integrating artificial intelligence tools into everyday work. The Big Four accounting and advisory firm started piloting AI immersion sessions in October, with a full rollout to new US associates slated for July. The sessions are happening across PwC's tax, assurance, and advisory business. "We truly believe that the role of the new associate will be changing with AI and that their role will become somewhat elevated, and we need to make sure that we're really training them on those skills to work and think differently," said Margaret Burke, the firmwide talent acquisition and development leader for PwC US. Like its competitors, PwC has recently funneled resources into next generation autonomous tools aimed at handling routine tasks solo. The firm said in November it shed about 150 jobs across marketing, human resources, and other US support roles as part of a longer-term effort modernizing its back-office unit, including through using new AI tools. In this week's Talking Tax, Burke and PwC US Tax Leader Krishnan Chandrasekhar sat down with Bloomberg Tax reporter Jorja Siemons to discuss how the AI trainings have gone so far and what skills they hope new employees learn. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
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    17 min
  • Tariffs, Big Audits, Roil Transfer Pricing Heading Into New Year

    Tariffs, Big Audits, Roil Transfer Pricing Heading Into New Year
    Dec 10 2025
    A slew of big tax disputes and the worldwide upheaval brought on by the Trump administration's aggressive trade policy made for an exceptionally interesting year for transfer pricing professionals, and left them with lingering questions heading into 2026. President Donald Trump's April tariff announcements sent shock waves through the global economy and forced corporate tax heads—and C suites—to start figuring out what it all meant for their tax and transfer pricing positions, and whether they needed to make changes to fend off potential audits. At the same time, companies are seeing a growing number of audits and transfer pricing disputes—often with big dollar figures—as tax authorities around the world beef up their auditing and enforcement capabilities with staff, AI, and stronger reporting requirements. Auditing multinationals can bring them big tax rewards. That might be less true at the IRS, where the Trump administration has drastically reduced resources and staffing. On this episode of Talking Tax, Bloomberg Tax transfer pricing reporter Caleb Harshberger discusses what's been going on in the world of transfer pricing—which governs transactions within corporate groups—and what he's keeping an eye out for next year. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
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    13 min
  • Taxpayers 'Gamble' by Committing Fraud, Even With Diminished IRS

    Taxpayers 'Gamble' by Committing Fraud, Even With Diminished IRS
    Dec 3 2025
    Anyone thinking about pushing the boundaries of tax law should remember that there's no federal statute of limitations on prosecuting fraud, even with weakened IRS enforcement, said Carolyn Schenck, who spent 20 years at the agency primarily combating tax evasion. "If people think that a current administration or a past administration might go soft on tax fraud, that's still an awfully big gamble," said Schenck, who's now at Caplin & Drysdale. "And I know that that's not one I personally would want to take." The IRS is coming off a tumultuous year with deep staffing cuts from the Trump administration's efforts to downsize the federal government and a parade of new commissioners. But increasing IRS staff and resources would be one of the best ways the government could combat fraud and collect more of the money it's owed, Schenck said. On this episode of Talking Tax, Schenck sat down with Bloomberg Tax reporter Erin Schilling to discuss what Trump administration workforce cuts mean for IRS enforcement and how the agency could improve its efforts to go after illegal tax shelters, even with a diminished staff. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
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    15 min
  • Cross-Border Tax Fraud an Old Story, Roman Scroll Shows (Rerun)

    Cross-Border Tax Fraud an Old Story, Roman Scroll Shows (Rerun)
    Nov 26 2025
    For the holidays, we serve up an encore presentation of a Talking Tax podcast that shows cross-border tax fraud has been around a long time. When researchers studied a previously mislabeled scroll, they discovered detailed attorney notes for a case against taxpayers accused of using forged documents and sham transactions between the Roman provinces of Judaea and Arabia to escape taxes on their assets. The assets in question were enslaved people. The potential punishments included distinctly unmodern measures. Anna Dolganov of the Austrian Academy of Sciences talked with reporter Caleb Harshberger about how scholars made the discovery, details of the scheme, and what they’re hoping to uncover next as they continue their research. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
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    15 min