This transcript has been edited for length and clarity.

David Stewart: Welcome to the podcast. I'm David Stewart, editor in chief of Tax Notes Today International. This week: taking credit.

The employee retention credit, part of the pandemic-era relief, has done something few tax credits do. It's gone mainstream. People around the U.S. are hearing about the credit and what it could potentially do for their business with often misleading, verging on fraudulent, pitches made in TV commercials and phone calls.

So what is this credit and why is it such a big deal now, three years later? Tax Notes legal reporter Caitlin Mullaney will talk about that in just a minute.

Later in the episode, we'll hear from Tax Notes State author Naomita Yadav about U.S. and U.K. inheritance and transfer tax law.

But first, Caitlin, welcome back to the podcast.

Caitlin Mullaney: Hi, Dave. Thank you so much for having me. I always enjoy being on the podcast.

David Stewart: Now I understand you talked to someone about the ERC. Could you tell us about your guest?

Caitlin Mullaney: Yes. I was recently able to speak with Tom Cullinan. He's a shareholder at Chamberlain Hrdlicka in Atlanta. Tom was previously with the IRS, where he served as part of Commissioner Charles Rettig's leadership team as his counselor and acting IRS chief of staff, and he has over 25 years of experience representing taxpayers in IRS interactions.

David Stewart: So what sort of issues did you talk about?

Caitlin Mullaney: Well, we discussed everything ERC. While it's a credit that only applies to employers, as you mentioned, it's had a surprising entrance into our daily lives, whether it's those spam calls we've all been getting telling us that our nonexistent businesses are eligible for $26,000 refunds or seeing Ty Burrell, the actor behind the beloved TV character Phil Dunphy, in a marketing campaign for a refund company that focuses on ERC claims.

David Stewart: All right, let's go to that interview.

Caitlin Mullaney: Well, Tom, first of all, welcome to the podcast.

Tom Cullinan: Thank you. I'm really excited to be here.

Caitlin Mullaney: Well, we're happy to have you here. Now, before we deep dive into everything ERC-related, do you want to give the listeners just a general explanation of what the ERC is?

Tom Cullinan: At a high level, I think of it as a lifeline to a lot of small businesses that were hurt by COVID. There's a lot of technicality to it. First, most people just call it the ERC, but it's a refundable tax credit for businesses and tax-exempt organizations that had employees and were affected during the COVID-19 pandemic. It's available to eligible employers that paid qualified wages to some or all employees during 2020 or 2021. So it's over now, but qualifying businesses still have some time to file refund claims for prior periods. So that's why we're still seeing a lot of activity. And it can be a lot of money, up to $26,000 per employee.

The requirements are different depending on the time period for which someone's claiming the credit. So you really need to focus in on the rules, but generally there are three ways to be eligible. You can experience a full or partial suspension of operations resulting from a government order issued due to the pandemic during 20[20] or the first three quarters of 2021. You can experience decline, a specified decline in gross receipts during those same periods, or you can qualify as a recovery start-up business for the third or fourth quarters of 2021.

Caitlin Mullaney: Great. Thank you so much for giving us that explanation. Now let's jump in. Tom, you were actually at the IRS when the ERC was implemented. What are your thoughts on where the credit and more specifically claims for the credit stand three years later?

Tom Cullinan: Well, the interesting thing is now I've seen it on both sides. So yes, I was at the IRS at the time, but now I'm representing clients that have claimed the ERC, and I've seen what it can mean to their businesses. It really is an important program. But starting with the IRS, I'm just extremely proud of what IRS employees accomplished.

And when I say that, my words were intentional because the IRS is an organization of employees. These people may be our neighbors; they shop in the same grocery stores; they go to our churches; and when COVID came, they, like the rest of the United States, had a wide range of reaction. Some of them were really scared, but they delivered.

And when we talk about the ERC, I think we need to all keep in mind that it was really just one piece of what the IRS was asked to do, which included the IRS delivered three rounds of the economic impact payments, also known as EIP. And I went back yesterday and did some math, and according to my computations, it totals out to 475 million payments totaling more than $800 billion. They were doing a tremendous amount of outreach trying to get the money to everybody who was entitled to it. And in some cases, that was easy enough to make a direct deposit into somebody's account. But the IRS was also looking to get money to homeless people without bank accounts. There was just a huge amount of outreach and stakeholder involvement in that.

Then you also had — the IRS was obviously tasked with processing the filing season. It was collecting taxes, which are $3.5 to $4 trillion. It was implementing and delivering the advance child tax credit, trying to answer an overwhelming number of phone calls. At one point, the IRS was getting 1,500 calls per second. And then there was the ERC, which obviously also is a tremendously important part of that.

Recently the IRS reported that it received 2.5 million ERC claims. I don't have any recent data that I could find on the total value of the refunds, but it's certainly in the tens of billions of dollars. And as I said, I've seen firsthand how critical that program was to small businesses. I've had clients and just colleagues and people I know tell me how much of a savior it was to their businesses. So it really mattered, and I think the people that were involved should be very proud of the work that they did.

Caitlin Mullaney: Wow, those are some big numbers. Thank you very much for that insider insight. And with implementing the ERC, what would you say was the biggest challenge for the IRS?

Tom Cullinan: So at first, of course, the IRS was trying to administer all this while dealing with COVID, the effects of COVID on its own operation and its employees. So again, we just need to keep that in mind. But then as things progressed, I think, and this is pretty well known, that one of the biggest challenges were the [Forms] 941-Xs, which is the form that you're going to file for the claim is on paper.

And so that means the IRS needed people to work each one of the claims, which is very resource-intensive. And as I said a moment ago, just a few weeks ago, the IRS had reported that it had received 2.5 million claims. So you can just imagine the manpower that was necessary to pull all that off.

And then there's a real tension between diligence and speed. On the one hand, the IRS was trying to get these refunds out as quickly as it could. It well understood that businesses were depending on it, and it took that very seriously.

On the other hand, the IRS knows that there's a lot of fraud in this space, and I'm sure it's doing what it can to screen those claims out at the front end, but obviously the more focus you put on the claims at the front end, that can slow down the process a bit. So it's a hard balance to strike.

Caitlin Mullaney: You mentioned a lot of things that I'd like to address throughout the podcast. One of the things you previously mentioned was that you're currently representing employers with their claims. Are there employers that are actively still finding out about the credit, finding out about their eligibility for the credit? Or are these just ongoing claims that they've been working on for the past three years?

Tom Cullinan: Some are claims that have been filed, so they're obviously anxious about getting their refunds, but there are still folks out there who, for whatever reason, didn't think they were eligible or may have been told that they weren't eligible and now they're having second guesses about that. So we do still see some people coming in that have real eligibility issues.

Caitlin Mullaney: Interesting. And with that, do you think that further guidance regarding the ERC is needed from the IRS?

Tom Cullinan: The IRS has put out a lot of guidance already on IRS.gov. There have been several notices. There are FAQs. The hardest questions, in my mind, are case-specific. For example, whether there was a full or partial suspension of operations resulting from a government order due to the pandemic. That's very fact-specific. The IRS has given examples, but it's going to be up to the advisers to apply those examples to a particular business situation to make an assessment of whether the business is eligible or not. And that's what we do. But I think it would be hard for the IRS to really be more specific about how exactly to apply that.

And then of course, you've got the fact that the clock is ticking. Many businesses have already filed. So guidance is going to have less and less effect as time goes on. And when I say that the clock is ticking, there are time limits. As I said, we're still seeing activity because people can go back and amend for prior periods, but the deadline for any period in 2020 is April 15, 2024, and the deadline for filing for a claim for any period in 2021 is April 15 of 2025. So you've got these end dates. And so with that, I think the value of IRS guidance, as every day passes, is diminished little by little. So I wouldn't expect them to do anything earth-shattering at this point.

And of course, there's been a lot of recent litigation about how the Administrative Procedure Act applies to the IRS, so if they were going to do anything earth-shattering, so to speak, that might be something that would need to be done by regulation, and that can take just an awfully long time, unfortunately. So again, given the fact that we've got these deadlines coming up, my personal view is that I don't expect to see anything significant.

Caitlin Mullaney: Do you think there's a scenario where we see an extension of those deadlines?

Tom Cullinan: Actually, I don't. In fact, recently there have been some suggestions that the deadlines could get pulled back. Commissioner [Daniel] Werfel was quoted a couple of weeks ago — he was in Atlanta [at] the National Tax Forum that the IRS puts on, and he was quoted as saying that he's made some outreach to Congress about perhaps shortening the date.

And I read some members on [the House Ways and Means Committee] seem to be receptive to at least having that conversation. So I think that there's at least something going. Of course, it's up to Congress to act, but that there's at least some push to accelerate rather than extend.

Caitlin Mullaney: Interesting. And as you mentioned, I would imagine that contributes a lot to the urgency of a potentially fluctuating deadline.

We're going to go in a little bit of a different direction now. One area we have seen a lot of IRS releases has been warnings against misleading claims and scams from aggressive promoters about the ERC at so-called ERC mills. Let's talk about those. What exactly is an ERC mill?

Tom Cullinan: I don't think there's a standard definition, or at least there's not one that I've ever seen, but in my mind, it's cold-calling with promises without even knowing your situation. It's one of those "I know it when I see it." I've gotten cold calls. I got cold calls when I was the IRS acting chief of staff telling me that my LLC qualified for the ERC.

First, I don't own an LLC. I was at the IRS at the time. I was just amazed that somebody is leaving me these messages. And within a few weeks after that, my wife was sharing with me emails and texts that she was getting telling her that she qualified, not that you may qualify or that there's a question or we've seen something to suggest that you might qualify. It was [a] flat-out statement: "You qualify for the ERC; you're missing out on $26,000 per employee." And then my youngest daughter started getting them. I almost felt like playing a couple of them for the podcast, but I guess my better judgment got ahold of me.

And then I've seen too on LinkedIn really, a lot of people are sharing, in the practitioner community, some of the more aggressive pitches, and you see that some of these outfits are putting together letters that actually look like they come from the IRS. They're sending them to, again, businesses, and that's a hard thing for a business to react to. You get this letter; it looks like it comes [from] the IRS; it's telling you that you're eligible for this. All you need to do is pick up the phone, call the 1-800 number, and they'll walk you through the process. I would absolutely consider that a mill.

Caitlin Mullaney: I've actually gotten a few of those calls myself offering $26,000 in refunds for my nonexistent business. Can you give an insight on the IRS response to the issues resulting from these ERC mills?

Tom Cullinan: There's certainly been no shortage of warnings. I think the IRS has done a good job of warning businesses to be wary. One thing that I think that may come out of this is authority for IRS to regulate return preparers. 

That's something that [the] IRS has been asking Congress for authority to do for years, and maybe this is something that finally prompts Congress to act because we're seeing congressmen and senators pretty consistently express some concerns about what's going on in this space.

They listen to the radio just like we do. They're getting phone calls from mills just like other people are. I think they understand that there are real issues here, but without the authority to regulate return preparers on the front end, I think the IRS has really been focused to, well first screen the — as best they can — screen the claims that are coming in the door. But again, you get back to that tension that they understand that businesses need the funds so that they're trying to just ride that balance.

But as to shutting down the mills, what the IRS is doing is more of a kind of back-end approach again, because they can't really regulate it at the front end, and they're doing that through criminal investigations or promoter audits or both, and they've been pretty transparent about that.

There's been a lot of public messaging, and they're doing that obviously to try to influence behavior and let folks know that they're very involved in this space and there can be quite serious consequences for people that are doing bad things.

Caitlin Mullaney: Do you think we're going to see a lot of tax crime cases coming out of these mills and the improperly claimed credits as a result?

Tom Cullinan: I do. I think it's notable that one promoter already pled guilty to aiding in the filing of false returns in Utah in June of last summer, so June of 2022. Criminal cases usually take a long time to develop, so that was really fast, which signals to me that IRS-CI, CI is Criminal Investigations, is very involved and has been for a while.

The IRS doesn't generally share [the] number of investigations, so I wasn't able to find any information directly from IRS, but they also respond to letters from congresspeople, and a couple of congresspeople have shared information. So I've seen reports again from congresspeople who are apparently sharing what they got from the IRS that as of just this past April, the IRS had 122 open criminal investigations involving more than $1.2 billion of potentially fraudulent ERC claims.

So that's a lot of work. That's a lot of activity, which would, yes, lead me to believe that we're going to see more criminal cases and the IRS knows there's a lot of fraud here. You can see that in all the repeated press releases with warnings to taxpayers, and I think we're going to also see more audit activity. And one thing that I don't know that it's gotten as much publicity, but when Congress enacted the law, it also gave the IRS more time to audit.

In a typical case, the IRS gets three years, but with the ERC, Congress gave the IRS five years, so I think we might see more civil activity over that span as well. But of course, the IRS can't audit everyone. And one thing that the IRS playbook is to rely on [is] criminal investigations as a deterrent and to publicize it so when somebody gets indicted, it's a powerful warning to other similar actors. But again, building a criminal case takes a long time, and the deterrent aspect is waning as the clock for claiming ERC ticks down.

Caitlin Mullaney: And you mentioned audit activity, an increase in that. Do you think we'll see anything happening with the penalties that would be applied to taxpayers who were in the situation because they were scammed or misled?

Tom Cullinan: That's a hard situation. There's just so much misinformation out there. And going back to the taxpayers who I was talking about a couple minutes ago, imagine you get a letter that looks like it's coming from the IRS, and it's saying, "Call this 1-800 number, and we'll help you qualify," and you call that number, and the folks on the other end could even pretend like they're at the IRS, and that taxpayer goes ahead and files for the claim.

It is just really hard for me to think that that's an appropriate place for a penalty. So I would anticipate that the IRS is just going to have to be flexible here.

As I said, I've gotten calls, my wife has gotten calls, my kids have gotten calls, and you said you've gotten calls, and some people can easily sift through all that, but for other people, it's harder. I just think there's going to have to be some relief, but then the hard thing really becomes you also have people that are trying to take advantage and parsing through those is going to be a case-by-case situation.

But I would again be hopeful that anybody who was scammed or misled which I guess is really your question if you were scammed or misled, I would hope that at the end of the day, the IRS would be very lenient.

Caitlin Mullaney: And with all these scams out there, what advice would you give to employers who are trying to claim the ERC?

Tom Cullinan: Well, I'd be wary of cold calls. Certainly you should be calling the advisers rather than the other way around. I did have one thought on this because I had read something maybe a week or two ago where folks were saying to be really wary of contingency fees, that's a huge red flag.

I've got a slightly different view on that. I mean, I understand what those people are saying, but I think it's also important to keep in mind that the whole point of the ERC was to really help cash-starved businesses survive.

And I wouldn't want eligible businesses to miss out simply because of a cost to participate, and a full analysis of eligibility can be expensive. If you're operating in a lot of jurisdictions, you've got a lot of different business lines [and] that could be costly.

So I can see a role that somebody doing this on a contingency basis can actually add some value.  Again, that's consistent with, in my view, the point of the ERC in the first place. But of course, those are policy calls.

Caitlin Mullaney: Do you think that this ERC program is one that we could potentially see replicated in the future?

Tom Cullinan: Well, since it was a response to a global pandemic, I certainly hope not. But with that said, if there were to be something disastrous in the future, there is certainly history for Congress just taking what's already been done and cleaning it up and putting it back out there. Because I'm sure COVID also affected Congress and Congress's staff, and if there was something like that to happen in the future again, I'm sure they would start with what's already been done.

But yeah, there's a lot to learn from the program. I'm sure there could be improvements, so I wouldn't anticipate anything that looks exactly the same, but I think it would probably be a starting point.

Caitlin Mullaney: Finally, bringing it full circle where it stands. Do you think the credit has fulfilled its intended purpose?

Tom Cullinan: I do. That certainly, in combination with the EIP and the PPP and other programs, was really to keep the American economy from crashing, and it didn't. There was obviously a massive cost, but yeah, I'm not in a position to pass judgment on that.

Caitlin Mullaney: And now Tom, I'll just ask if you have any closing thoughts for us today.

Tom Cullinan: Just that I really appreciate being here. I think it's a very important topic; it was important to a lot of businesses. Again, having been on the inside of the IRS and now on the outside representing taxpayers, it actually reinforces my view that what the IRS was doing here was really important.

They should be proud. I see these taxpayers, how much it means to them; literally in some cases, they really need the money just to keep the business alive. So it's a critical program, and it's one that I was glad to even have just a small part of any piece of this.

Caitlin Mullaney: Well, we appreciated having you here to talk all things ERC with us. Sadly, that's all the time we do have for today. I want to again thank Tom for coming on the podcast. It was great having you with us today.

Tom Cullinan: Thank you for having me. I really do appreciate it.

David Stewart: And now, coming attractions. Each week we highlight new and interesting commentary in our magazines. Joining me now is Acquisitions and Engagement Editor in Chief Paige Jones. Paige, what do you have for us?

Paige Jones: Thanks, Dave. In Tax Notes Federal, three RSM US practitioners question if we're missing billions in hidden corporate tax subsidies. Five Chamberlain Hrdlicka practitioners examined charitable remainder annuity trust transactions, which the IRS has included on its "Dirty Dozen" list.

In Tax Notes State, Brian Howsare and Kevin Herzberg examine a significant change to the communication service tax in Florida. Michael Bernard explains that since Wayfair, states have come to rely on e-commerce sales tax as a stream of revenue, creating new standards for remote sellers.

In Tax Notes International, Kimberly Blanchard wonders if pillar 2's minimum tax and U.S. worldwide taxation can peacefully coexist. Tony Malik explains the credibility of contemporaneously paid foreign taxes.

In featured analysis, Nana Ama Sarfo reviews the OECD's latest Tax Transparency in Africa report. She notes how developments in trade and beneficial ownership transparency could help advance tax transparency on the continent.

And now for a look at what's new and noteworthy in our magazines, here's Tax Notes State Editor in Chief Audrey Pollitt.

Audrey Pollitt: Thanks, Paige. I'm here with Naomita Yadav, a partner at Withers in San Francisco, who regularly contributes to Tax Notes through her column, "(Tax) Matters of Life and Death." Welcome to the podcast, Naomita.

Naomita Yadav: Thank you so much, Audrey. Real pleasure to be here and always a pleasure to chat with you.

Audrey Pollitt: Likewise. We're here to discuss your Tax Notes State article "Sparing No One: Cross-Border Taxation of Globally Mobile Individuals," the second in a two-part series. The first, the cover story of our June 19 issue, illustrated the transnational income tax consequences of Prince Harry and Meghan Markle's move to California. Could you tell us a bit about this latest installment?

Naomita Yadav: Yeah, so part 1 focused on income taxes, and part 2 is focusing on transfer taxes. So gift estate in the U.S. and inheritance tax in the U.K.

Audrey Pollitt: Something that jumped out in part 2 was the pattern emerging from the seemingly disparate decisions around domicile and how the intent to create domicile can be informed by the presence or absence of a goal when someone is moving to the U.S. Could you speak a bit on that?

Naomita Yadav: Yeah, absolutely. So taking a step back here, in some sense, the test that one uses for income tax purposes is a little bit more cut and dry because they rely more, at least at the federal level — California is a whole different thing — but at the federal level, you have a very clear days test.

So for the most part, people will be able to easily determine if they're subject to U.S. federal income taxes based on a more clear line test. You count the number of days that you spent in the country over the last three years, and then absent something that goes into more like — usually the test stops there. There are other tests under the treaties, etc., but usually for that, that is enough.

The transfer taxes, which is gift estate in the U.S. and in the U.K., the inheritance tax, they all rely on this concept of domicile. And unlike a clear days test, domicile is all about subjective intent. So it is all about, almost, what do you consider your home?

And what is home is very — how do you know where someone's home is, especially if the person is globally mobile, where they may have multiple actual residences, like you own five properties and you spend a fifth of the year in five places. Well, where is your home? Can you even have a singular home?

Both countries still rely on this idea that your domicile, your home, is a singular place. Though, if you will see in the article itself, I talk about this Supreme Court decision, Texas v. Florida, which is from way back, from the '30s, where also there's a whole discussion of whether or not this concept of domicile and the singularity of domicile is applicable.

Now, that was actually a state case, which I found very interesting because you had states within the U.S. that were arguing about a decedent's domicile as to where their estate can be taxed. And there's a very interesting dissent in there, which is talking about the whole question was whether the Supreme Court even had standing.

But that discussion, I thought, was very interesting because way before what we are thinking about now, those questions were even arising then, maybe not in the context of people living in different continents, but definitely even within the country.

Audrey Pollitt: Sure. Well, and I think what you're also referring to from the article is how we are so remote work heavy, how there's much more global mobility than there was when that decision was authored, which feels like a significant amount of time to still be considering it for guidance when the facts are so different than they are now.

You were talking a lot about how these considerations are fact-intensive inquiries and really circumstantially specific. Could you say a little bit more about that?

Naomita Yadav: Yeah. One of the things that I've run up against, and actually this is something I've referred to even in one of my other articles that I've done last year for you, which is very specific to California residency.

Just as a quick aside: California residency actually is not a clear days test. The idea of California residency is much more like the concept of domicile than not. They talk about a temporary transitory test, so they say that, are you in California for a temporary transitory purpose? But all of this, whenever you have a subjective test — what is your home? Are you here for a "temporary transitory purpose?" — it

all goes to intent, and objectively proving subjective intent can become complicated. And a lot of times I think, especially when I work with clients on these issues, what I find is that people want a cut-and-dry answer: "Give me a checklist. If I check off all of these things, then I am clearly not a resident. I don't have these things."

But these are not cut and dry, so I always try to tell them that anything — they might have seen checklists, and if you Google these topics, there are a lot of things that come up with different checklists derived from different case laws, and I say that those are perhaps necessary but not sufficient.

I mean, some of these things like if you are clearly maintaining a residence and your family is continuing to live in a place, your ability to be able to argue that that is not your home becomes much weaker. It's not to say that's a zero argument, but whenever you have subjectivity, then it's like you have to convince the other person that this "smells right."

Audrey Pollitt: Sure. Well, when you're looking at something that is so subjective, absent somebody who severs all ties to a second country and absent some clear expression of intent to remain permanently, are there any factors that you would feel comfortable weighing as more outcome-determinative than others?

Naomita Yadav: Yeah, I mean even in this article, we are exploring that very question in the context of Prince Harry specifically. We are saying that on the one hand, there are some objective things that are very much public information, such as that he resigned as a senior royal, he's been asked to give up Frogmore Cottage, etc.

So if this were just like a normal family, and you said, "OK, somebody was an officer in the family business and then they resigned," and then they gave up all of their association with the company, and then they were asked to give back the keys to the apartment and then they moved to a different country, you would say, "OK, the factors are really building up to say that maybe the intent is very clear that they don't really want to be there anymore," but it isn't the case.

I mean, it isn't just a company, right? It is the world's oldest monarchy, so it makes for a very unusual fact pattern. But even for more normal situations, so supposing it was a company, in that situation also, one would want to see — one would definitely want to get into the treaty.

Number one, you'd have to see the treaty tiebreaker and make sure that if you don't have absolute clarity, where would that tiebreaker land you? And maybe work backwards from there. So say, OK, the treaty tiebreaker will qualify me as a U.K. domiciliary or a U.S. domiciliary. If I don't want that answer, then I have to move back and say, "All right, what are the factors that I have to really try to build up to make sure that if my intent is like I know what my intent is, but how do I objectively prove it?"

Audrey Pollitt: Well, I know that when I'm trying to establish U.K. domicile, I'll be coming to you first.

Naomita Yadav: My first thing would be, are you sure you want to go to another heavy-taxed jurisdiction?

Audrey Pollitt: I will move wherever you think is most prudent. Can we expect a part 3? Anything more on Harry and Meghan from you?

Naomita Yadav: I think we've kind of wrapped up this topic pretty well for now. I think our readers would probably also like something other than another 6,000-page, not page, but word article on our poor beleaguered U.S.-U.K. relations.

Audrey Pollitt: Well, we look forward to publishing part 2 in our August 14 issue. Before we let you go, where can listeners find you online?

Naomita Yadav: Obviously there's this podcast, and then I'm on LinkedIn. I also try to, anytime anything comes out, I do put a blurb out on my LinkedIn profile, and then my firm has all of the articles that I've done, published under my bio on the firm website, so you can find links to pretty much everything on there.

Audrey Pollitt: OK, great. Thank you for joining us on the podcast, Naomita.

Naomita Yadav: Thank you so much, Audrey.

Audrey Pollitt: You can find Naomita's article online at taxnotes.com, and be sure to subscribe to our YouTube channel Tax Notes for more in-depth discussions on what's new and noteworthy. Again, that's Tax Notes with an S. Back to you, Dave.

David Stewart: That's it for this week. You can follow me online @TaxStew, that's S-T-E-W, and be sure to follow @TaxNotes for all things tax. If you have any comments, questions, or suggestions for a future episode, you can email us at podcast@taxanalysts.org. And as always, if you like what we're doing here, please leave a rating or review wherever you download this podcast. We'll be back next week with another episode of Tax Notes Talk.

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