The US is entering a 3-year period of tax volatility and turbulence. Tax professionals know what’s coming, but do you?

  1. The sweeping tax laws passed in the Tax Cuts and Jobs Act of 2017 are set to expire in 2025. What are the likely scenarios, and how will they affect US taxpayers?
  2. The US government is split and facing party infighting. Will politicians be able to muster enough cooperation to pass new tax laws and prevent an abrupt return to pre-2017 tax law? What will happen if they can’t?
  3. The US elections will take place later in 2024. How might these affect the impending expiration of 2017 tax laws and the government’s ability to enact new tax legislation? Will states conform to new federal tax legislation?
  4. Multiple significant court cases have been making their way through appeals processes in the Tax Courts and Supreme Court. What will the decisions mean for you?
  5. The IRS has issued more proposed regulations than ever before, in reaction to multiple challenges under the Administrative Procedures Act (APA). How will this affect your tax returns now and in the future?

Our podcast, scheduled to launch in mid-2024, will keep you abreast of the most important developments during this turbulent time.

Specifically, it will provide:

  • Explanations and interpretations of current events that affect US taxpayers
  • Master classes in various US tax topics of interest to international and domestic audiences
  • Updates on hot topics in US tax
  • Commentary on how these complex tax issues affect everyday US taxpayers

We have already recorded our first episodes, and we look forward to launching them soon on Spotify, Apple, and other platforms.

Episode 1: The Wolf Group Story and Current Outlook

Len, Mish and Bob

Bob Len, Mishkin Santa, and Len Wolf meet to record Episode 1.

Principal Mishkin Santa interviews long-time partners Len Wolf and Bob Len on how The Wolf Group got its start and the biggest challenges facing tax firms today.

Episode 2: Implications of the Supreme Court Decision in the Moore Case

On June 20, 2024, the Supreme Court issued a narrow ruling upholding the constitutionality of the transition tax in Moore v. United States. The Court did not address issues related to pass-through taxation, realization events, and a potential future wealth tax. The ruling preserves the tax laws related to foreign corporations that were ushered in via the 2017 Tax Cuts and Jobs Act.

In this episode, Mishkin Santa will provide a background on the history of US taxation of foreign corporations and foreign income/assets, how we got to the 2017 Tax Cuts and Jobs Act, why the Moore case came about, and the specific issues the ruling will impact for everyday taxpayers. Mishkin will interview attorney Austin Carlson to get his general takeaways on the ruling in the Moore case and discuss the impact of the ruling as it relates to Offshore Voluntary Disclosure Practice. Lastly, Mishkin and Austin will discuss current issues related to IRS amnesty programs for US individuals that have not properly or fully disclosed foreign financial assets and income and the impending sunset of the 2017 Tax Cuts and Jobs Act at the end of calendar year 2025.

Episode 3: June 2024 Hot Topics in US/International Tax

What’s been in the tax news lately, and how might it affect you? Mishkin Santa covers a range of topics, including IRS scams, erroneous IRS notices, UK developments that affect US/UK taxpayers, court cases on foreign asset reporting, proposed tax regulations for foreign trusts and foreign pensions, and more.

Further Episodes

We are currently scheduling production of additional episodes on topics such as:

  • The impending expiration of current tax laws (from 2017) and challenges for US taxpayers
  • US-UK Cross-Border Tax Planning: Impact of UK general elections on tax law
  • US-Switzerland Cross-Border Tax Planning: New Swiss Family Foundation
  • US-Italy Cross-Border Tax Planning: Flat Substitute Tax Regime
  • US-Poland Cross-Border Tax Planning: New Polish Family Foundation
  • New IRS regulations on US Exit Tax (for US citizens and long-term residents giving up their US citizenship/residency)
  • New IRS regulations on partnership tax matters
  • New IRS regulations on foreign trusts
  • Foreign ownership of US real estate (FIRPTA) matters
  • Updates to US income tax treaties, including those with Chile, Russia, Switzerland, and Israel
  • Recent IRS guidance that all US taxpayers should be aware of

Stay tuned! Keep an eye out for our official launch announcement in the coming weeks!