In this episode of Tax Notes Talk, former IRS Commissioners Lawrence Gibbs, John Koskinen, Charles Rettig, and Daniel Werfel share lessons learned from their tenures and predictions for the agency’s future under the new administration. Tax Notes Talk is a podcast produced by Tax Notes. This transcript has been edited for clarity. David D. Stewart: Welcome to the podcast. I am David Stewart, editor in chief of Tax Notes Today International. This week: commissioners of IRS past. Since President Trump took office in January, the IRS has been in the spotlight. We’ve previously covered how the agency is handling staff…

Although Tax Court Judge Cary Douglas Pugh rejected the IRS’s position on almost every key methodological detail in Facebook Inc. v. Commissioner, 164 T.C. No. 9 (2025), her opinion vindicated the general legitimacy of the method and the regulatory scheme that introduced it. Like most other major section 482 cases, especially those involving contributions to cost-sharing agreements (CSAs), Facebook was largely a clash between the parties’ economists. Both sides leaned heavily on valuation reports by expert witnesses to support their vastly differing valuations of Facebook’s platform contributions to a 2010 CSA with its Irish subsidiary, which included core technologies and…

Deregulation has been a cornerstone of the Republican brand for decades. And the Trump Administration vows to cut government red tape wherever it finds it. Yet, House Republicans would use their just-passed budget bill to create reams of paperwork explicitly intended to block low- and moderate income households or immigrants from government assistance to which they are legally entitled. Just as progressives have used environmental regulation to halt development they don’t like, President Trump and his allies on Capitol Hill are creating new bureaucratic hurdles to prevent families from tapping government benefits. And they are doing it just when Democrats…

Following a lengthy legal battle, the AP reports that Judge Claudia Wilken has approved a deal between the NCAA and lawyers representing NCAA athletes. While the deal is nuanced, the key takeaway from this deal is that schools can now begin paying athletes directly. This change represents a significant departure from the NCAA’s longstanding tradition of its athletes being student-athletes, hence remaining amateur (and unpaid) during their time in college. Although this coming year will be the first time that college athletes will begin to get paid directly by their schools, athletes receiving millions of dollars has become a mainstay…

Most lawsuit settlements are taxed, but there’s an important exception: compensatory damages for personal physical injuries or physical sickness are tax free under Section 104 of the tax code. However, exactly what qualifies has been hotly debated for decades. Damages for emotional injuries are fully taxable, yet if you have emotional injuries triggered by physical ones, the damages for the emotional injuries are also tax-free. It can make taxing emotional distress and physical sickness a kind of chicken and egg issue. Settlement wording matters, as does the complaint. Adding to the confusion, exactly what is ‘physical’ is not defined. Traditionally,…

Agentic commerce is a new way of shopping where AI agents (smart computer programs) do the shopping for you. Instead of having to search, compare, and buy things yourself, you can tell an AI agent what you want, and it will take care of everything. These agents don’t just suggest products — they can actually make decisions and complete the purchase for you, using your saved payment methods. You still stay in control by setting the rules and determining what the agent is allowed to buy. Using smart purchasing agents may save you time and effort. Rather than having to…

A year or so after graduating from law school, my husband and I bought a house in Philadelphia. Two years later, we got a dog, which sent me scurrying online to find a dog walker. My husband had moved over to an AmLaw 200 firm by that point and he was working long hours. I was working for a midsize firm in the city and my hours were just as long. We left home pretty early in the morning and often met to eat dinner out in the City. We paid someone to clean our house and mow our lawn.…

The IRS has assessed $4 billion in taxes, penalties, and interest on Yum! Brands. The issue stems from a tax-deferred reorganization in 2014. Yum! Brands is now suing to prevent the IRS from collecting these funds. M&A is often among the most complicated tax issues large corporations face, which can often lead to uncertainty and scrutiny from the IRS. In this article, I discuss the Yum! Brand corporation, what happened in 2014, and why they are facing such a steep tax penalty now over a decade later. What Is The Yum! Brands Corporation? Yum! Brands is the parent company of…

When my husband and I opened our law firm, we were confident. We had a name, a business plan, office space, and a website. We had thought of everything—except paperwork. And more paperwork. We had not considered how much time we would spend sorting through canceled checks, bank statements, payroll stubs, and letters from various tax authorities regarding regulations. While, as a tax lawyer, I well understood that taxes needed to be filed quarterly, I hadn’t done the math: quarterly filings for federal, state, and local taxes meant 12 separate submissions a year, just for income taxes. We also had…

When you’re a small business, you may not have the resources (nor the need) for a full-time staff. You might choose to have one or two employees who work part-time, one or two who work full-time, or, depending on your circumstances, you might fill in the gaps seasonally by hiring temporary employees. From a tax and employment law perspective, all of them could potentially be your employees. Sometimes employers assume that only full-time, permanent workers are employees. This is not true. Employees can be full-time or part-time, seasonal or year-round, temporary or permanent. The question of how to classify workers…