Talking Tax

• Tariffs, Big Audits, Roil Transfer Pricing Heading Into New Year

  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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• Taxpayers 'Gamble' by Committing Fraud, Even With Diminished IRS

  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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• Cross-Border Tax Fraud an Old Story, Roman Scroll Shows (Rerun)

  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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• What Comes Next for the IRS and Tax After the Long Shutdown

  Congress is back after ending the longest shutdown in US history. But the bipartisan accord left funding for the IRS and Treasury Department ending in less than three months and the fate of the enhanced premium tax credits at the center of the crisis still unresolved. On this episode of Talking Tax, Bloomberg Tax Congress reporter Zach C. Cohen and Bloomberg Government health policy reporter Erin Durkin discuss next steps for appropriating funds for the IRS and Treasury after current funding runs dry Jan. 30, and potential legislative solutions to rising health-care premiums. 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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• Mamdani's NYC Tax Agenda Prompts Advisers to Caution Patience

  New York City Mayor-elect Zohran Mamdani ran on an expansive affordability agenda that would be paid for by higher taxes on corporations and wealthy individuals. The democratic socialist's vision will be tough to realize, though, because any tax hikes would have to be approved by the New York State legislature and tax hike-averse Gov. Kathy Hochul (D). Local tax practitioners are emphasizing this political reality to worried clients who called and emailed in a hurry after Mandani won the Nov. 4 mayoral contest. “There’s been kind of some demystifying as to how can or how will the mayor be able to make these ideas or proposals law," Jeremy Gove, a state and local tax counsel at Eversheds Sutherland, tells Bloomberg Tax editor Benjamin Freed on this week's episode of the Talking Tax podcast. "Explaining this to taxpayers is what we’ve been tackling over the past week or so.” Gove says that while higher taxes could compel some New York companies and wealthy individuals to decamp for lower-tax states, there's also a "wait and see" sentiment prevailing. Taxpayers might even welcome some proposals from Mamdani, such as hiring more auditors to clear out the Department of Finance's hefty case backlog, he says. 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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