David D. Stewart 0:03

Welcome to the podcast. I'm David Stewart, editor in chief of Tax Notes Today International. This week: show me the crypto. Cryptocurrency's rise in popularity has led lawmakers in the United States to pursue a crackdown on how digital currency is taxed and regulated. The latest proposal making its way through Congress would increase cryptocurrency information reporting requirements. So how would the proposed requirements affect the tax community at large? And could there be more changes down the road? Here to talk more about this is Tax Notes contributing editor Marie Sapirie. Marie, welcome back to the podcast.

Marie Sapirie 1:37

Thanks for having me.

David D. Stewart 1:38

Now to begin with, could we start with some background on the proposed reporting requirements?

Marie Sapirie 1:43

The reporting requirements that are proposed in the infrastructure bill add new definitions to clarify who is a broker and what is a digital asset. If you're a broker, you have to submit information reports to the IRS and customers. There are also proposed changes that would require any recipient of more than $10,000 in digital assets in the course of a trade or business, either in a single transaction or in multiple related transactions to report the receipt of those assets.

David D. Stewart 2:09

So where do these provisions stand today? And are we expecting to see any changes before the final bill?

Marie Sapirie 2:14

It's always risky to try to predict exactly what Congress will do, but given that the reporting requirements in the infrastructure bill have a revenue estimate of $28 billion and we're closing in on the September 27th deadline for the infrastructure package vote, it's a reasonable bet that there won't be many changes to the proposal. However, the guidance drafting process that would follow the passage of the bill will definitely be more comprehensive and afford opportunities for industry players to make their case as to how the rules should apply. That's the most likely point at which there may be some adjustments to the scope of the rules.

David D. Stewart 2:47

Now cryptocurrency has been kind of a free willing area of finance. So how has the crypto community reacted to these new reporting requirements?

Marie Sapirie 2:56

Well, reading social media might give the impression that the proposal took the industry totally off guard, but it didn't quite come out of nowhere. Certainly Treasury and the IRS have been working on digital asset tax issues for years and even on Capitol Hill, there were indications earlier this year, that reporting requirements were coming. Also, most of the criticism is directed to the scope of the requirements, which is broad. Industry groups have been asking for guidance about reporting for some time, so the frustration is largely directed to the breadth of the proposed requirements and the seemingly small chance that they will be trimmed back before the infrastructure bill is passed .

David D. Stewart 3:33

You recently spoke with someone about this. Could you tell us about your guest and what you talked about?

Marie Sapirie 3:37

I spoke with Jordan Bass, he's a tax lawyer and CPA and the founder of Taxing Cryptocurrency and Bass Law. We talked about all of the currently proposed provisions and their potential effects for taxpayers and the digital asset industry. We also went over the newly proposed constructive sale and wash sale rules that are in the House Ways and Means Committee Democrats proposal that was just released.

David D. Stewart 4:00

All right, let's go to the interview.

Marie Sapirie 4:04

Thank you Jordan for joining me today to discuss the rapidly changing tax rules and in particular, the tax information reporting rules for digital assets.

Jordan Bass 4:13

Thank you for having me, looking forward to having this discussion.

Marie Sapirie 4:16

There are proposed legislative changes to tax information reporting for digital assets that are included as an offset in the infrastructure bill that Congress is currently working on. Before we get to those proposed changes, would you give us an overview of how the tax rules for cryptocurrencies and other digital assets have developed so far?

Jordan Bass 4:34

Yeah, of course. So the taxation of digital assets and cryptocurrencies has kind of been, the treatment has kind of been stagnant for a long period of time. Ever since we had the initial guidance released by the IRS in 2014. And even though people hadn't necessarily reviewed that guidance, there's been very, very straightforward treatment of most transactions since then. It's a trade for crypto to crypto would constitute a taxable event, a trade for crypto to cash would constitute a taxable event. If you're just purchasing the asset with U.S. dollars, of course, you're going to set up your basis in that asset, but that's not going to trigger any tax. That was basically the initial taxation treatment of these transactions. And then over time, the market kind of became more sophisticated, developed. There's been different sort of structures of transactions that have been created, you could say, with borrowing and lending on chain, providing liquidity on chain, in some of these decentralized exchanges and because the structures of the transactions have changed, the way that it's taxed has also changed. There were also in between, there were initial coin offerings (ICO's), there were airdrops that people would receive. There were forks from different chains and all of those events that changed how the initial tax treatment would be, where it was just a simple swap going from one coin to another, or going from U.S. dollars to a cryptocurrency or vice versa, created some complexity that caused confusion for a lot of taxpayers. And there wasn't really any guidance on those particular transactions until recently. There's so many different ways that a taxable event could arise in the digital assets space, not just what we've mentioned already, but even mining and staking your tokens, they're income generation events that again, haven't necessarily had that sort of guidance released by the IRS, but we can take existing tax principles and apply it to those transaction structures. And that's what we've been doing mostly for the last, six, seven, eight years that we've seen tax reporting done with crypto and digital assets. The main thing that has advanced the ability to report these transactions in a more clean way is there's been a lot of infrastructure built out from a software perspective and also an analytic perspective to actually see your transactions allocate cost basis. And then also determine what your proceeds were if there was a taxable event, if it was a trade, or see what the fair market value of the tokens were that you received on a day when you had an income generating event. But early on, that wasn't necessarily the case, so that may have caused a level of confusion and created complexity, additional complexity that maybe didn't need to necessarily be there with early crypto adopters. But all of that has led us kind of to the point where we are today, where there's a regulatory framework now and there's governmental bodies that are trying to regulate the space in an effort ultimately to A) in their mind, protect investors, but B) generate tax revenue from a space and a market that there may be an underpayment, so they believe, of tax liabilities from a lot of U.S. individuals and entities.

Marie Sapirie 8:08

Turning to the current debate in Congress, in the August draft of the infrastructure bill changes were proposed to the definitions of the terms, broker and digital asset. These changes have attracted some criticism, especially around the process through which the proposed changes are being introduced. The IRS had guidance under section 6045 on its priority guidance plan in 2019. But the legislative process is relatively new. First, let's look at the definition of broker because brokers are who's required to submit information returns to the IRS and to customers. Would you take us through the proposed definition of broker and the implications of this change?

Jordan Bass 8:46

Yeah, so really there were multiple amendments that were offered in the Senate to address this issue that we're going to be discussing, but ultimately the current definition is very, very broad for people in the crypto space. We believe that it is pretty broad and I'm sure on the other side, in the regulatory space, maybe that there needs to be additional guidance and so they say there will be to further define what this means. But any person, the definition is any person, for consideration that's responsible for regularly providing any service effectuating transfers of digital assets on behalf of another person. So in a way, this makes sense if the target is centralized cryptocurrency exchanges, which honestly in many ways function like the traditional broker dealers or traditional centralized exchange sort of platforms in traditional security markets. The Coinbases, the Krakens, the Geminis, the FTX U.S., the Binance U.S., and they have the ability to probably take on a lot of this information and report some of the transactions directly to, let's say the IRS, that they may have the infrastructure to do so. But the problem that a lot of people in the industry expressed concern with, and really we're looking for that revised definition is that, that definition of any person, it's very broad, could be interpreted to include people that are mining Bitcoin or other currencies, people that are maintaining a DeFi platform, a decentralized finance platform. Even though they don't have the information, they don't have that information readily available to report some of the transactions, they would still be included in that. For example, the miners in this space, they validate transactions, so in theory, they could be responsible for regularly providing any service that effectuate transfers of the digital assets on behalf of another person, but they don't have that information on who's the underlying parties and the transactions. Same thing goes with these DeFi platforms and protocols. They execute transfers, they execute transactions of crypto or help facilitate that based on something that's established in the code. But they don't really need any human intervention much different than a centralized exchange, like the example you talked about earlier, like a Coinbase, like a Gemini or a Kraken. And so this could also include many, many other non-custodial sort of actors in the crypto space. And I think it's more of an issue when you're talking about people that believe that the DeFi protocols that are being utilized are not necessarily, they have users, they don't have customers and they just allow people to utilize this software and they don't collect information like an entity or an exchange would when they KYC (Know Your Customer) their users or their customers in the centralized exchange sort of example. This could also include, proof of stake validators, I know we talked about staking. So this could include a lot of market participants, specifically really also, I think the regulation is more so garnered toward the DeFi space, the liquidity providers, something we mentioned earlier on as well. So it really just depends on how that additional guidance comes to play and comes out. But as of now, it's a very, very broad definition of what is deemed to be a broker for the section 6045.

Marie Sapirie 12:23

In addition to adding the broker definition, the proposal would also add a definition of the term, "digital assets." The proposed definition includes, "any digital representation of value, which is recorded on a cryptographically secured distributed ledger, or any similar technology as specified by the secretary." What are some of the possible effects of that new definition?

Jordan Bass 12:45

Yeah. So again, I think that this is another broad definition, obviously this would include digital assets, like people are familiar with Bitcoin or Ethereum or other stores or other cryptographically, the word they used , secured value, that's cryptographically secured it on a distributed ledger or any similar technology. But what this could also do is it could extend beyond cryptocurrency. So people are really focused on cryptocurrencies, things that we see in the market that kind of go up and down and very, very volatile let's say, but have had amazing returns for a lot of early on investors. But this could technically, and I think because it's very broad again, could apply to other digital goods. This could apply to another space that we've seen kind of boom of recent, which could be the NFT space, the non fungible token space. Because technically that asset could be a digital representation of value, which is what's in the definition and it's definitely recorded on chain or in some other sort of similar ledger in what they described in the amendment. So I think it has the ability to include more assets than just what we're talking about when we think of cryptocurrency. There could be a whole bunch of assets that become tokenized, that are stored on chain, that have some sort of digital representation of value that aren't necessarily what we think of today or what we see today. We have potential in the future to have security tokens. We have the potential for maybe some real property assets to be tokenized and represented with value on chain. So I think the definition is again, pretty broad, but as of now, I don't personally believe that there are any issues per se, with that definition. I think the big issue in the space mostly is related to what a broker is, but that digital asset definition does bring into play maybe something that could extend beyond cryptocurrencies, which again is basically the main point and the main issue with what is trying to be regulated, supposedly with these amendments.

Marie Sapirie 15:33

So the definition of "digital asset" clearly anticipates regulatory guidance with their similar technology as specified by the secretary. And it seems likely that there will be other types of guidance from Treasury and the IRS on other aspects of the proposed statutory changes, what would be helpful for Treasury and the IRS to consider while they're drafting that guidance.

Jordan Bass 15:55

So I think that the key in all of these issues, in my opinion, would be really focused on those centralized exchange actors that are really processing billions of dollars worth of volume on a day-to-day basis and trades. They're the ones where you really have the fiat on-ramp and off-ramp, and they're the places where you can really track, in my opinion, what's going on in the actual trading activity of an individual or an entity that is engaging in this market. So the key for me is really, if you really want to have this new technology, and specifically I do really believe this is about decentralized finance and the ability for people, some people think that there are activities occurring on chain without banks, and it can't be tracked. That's not true. That's really not true. It's all occurring on chain, so you can really, really see what's going on. But the way to kind of regulate this space, in my opinion, would be to focus on the centralized authorities that A) are definitely willing to comply with these regulations, because some of them like Coinbase are public companies, maybe some of them want to go public in the future and they don't want to be in any hot water with regulators. So if you focus on that space and you focus on the money going in and the money going out and have those individuals and those companies be the ones that are reporting this information and being forced to report this information, you kind of create this innovation-free zone for what's going on in the DeFi space, which is again, what I really think this is about, or even in the NFT space. And you allow for these companies to want to stay in the U.S. and not have feel the need to kind of move offshore. And we don't want to stifle innovation in this space because it does have the ability to generate from A) individual and an investor standpoint, a lot of wealth and a lot of asset accumulation for people in crypto, but B) those taxpayers are eventually going to have to pay tax when they either sell off a large portion of their assets if they're sitting in unrealized gain positions, or if they're utilizing these DeFi protocols and platforms to earn certain yields and earn income for the year. That's going to create income generation events for them, taxed at ordinary income rates, not even capital income rates, and the IRS will receive more tax revenue from that. Now the thing is, are those people going to report their income the right way and report and pay their tax liability the way that, maybe somebody who received a 1099, which I know we're going to talk about in a little bit, or somebody that would receive a W-2 from their employer. These are things that are tracked very easily by the IRS, and they can clearly see and match somebody reporting their income on the return and what they've actually received in terms of documentation that is required to go to the state and federal governments for tax purposes. But if the focus was on the centralized exchanges and maybe there were relationships created with these centralized exchanges, and there was an ability to track assets moving to and from centralized exchanges to unhosted wallets that aren't really custodied by somebody that has the ability to KYC their users. Then in theory, all of that tax money would come into the IRS. And if they had better tools to track this activity, which there are tools available, there are many firms that do this sort of on chain analysis that can see wallet address movement of crypto from one wallet to another. And if the centralized exchange helped the IRS in that case, because they're being regulated as such, and they want to make sure that they're complying with all the laws. And I think that's really where the focus should be, not indirectly killing a huge industry, a huge portion and sector of the crypto space like DeFi with regulation that maybe is unnecessary in a lot of people's opinion, but also just completely overbroad with lack of guidance being issued, which has kind of been a theme for the IRS or for any sort of regulatory body when it comes to crypto. Maybe people want this further guidance, but they haven't really received it over time. And if that's going to continue to be the case when we're talking about what a broker is, or what is included in a digital asset, then it's just going to continue to create confusion. And we don't want to have all these huge companies that are bringing billions and billions of dollars of value to the crypto space move and not want to set up their entities in the U.S. and move off shore and just completely stifled this industry in the United States. So that's really what I think is the most important thing is really focused on the centralized actors. I mean, you can worry about the people that are validators or mining or the DeFi protocols, but in a more of an indirect regulation, an indirect sort of cleaning up of that space by directly regulating the places where you can put money into the market and take money out of the market. Currently, there's no bridge to go from a DeFi protocol like compound or Aave to your Wells Fargo account, but there definitely is a way to go from your coinbased account to your Wells account. So those are the transactions that are currently can be tracked, and those are the ones that should be, those are the actors decentralized exchanges, in my opinion, that should be regulated.

Marie Sapirie 21:20

The broker definition has been a major focus recently, but there's another proposed change to section 6050I that would treat any digital asset, as defined in the proposed change to section 6045 that we just discussed, as cash for purposes of section 6050I, which also imposes reporting requirements. How would those requirements work and what are some of the potential consequences of this proposal that should be considered?

Jordan Bass 21:47

Yeah, so that's another big proposal because in theory, we have transactions that need to be reported every day when there's a certain dollar threshold that's met in cash. But if digital assets, if crypto is going to be treated as cash for the section, then in theory, any person that is engaged in a trade or business that receives or sends out $10,000 worth of digital assets, will have to report this information directly to the IRS. So what that would do, and again, the digital asset definition is defined very broadly. So this could include, like we've talked about, digital assets in addition to just crypto's, we may be the good example , so that would be like NFTs. But what that would do would create an additional reporting requirement that would provide the IRS with additional information. And ultimately what they're trying to do here is match what the amount of U.S. dollar value that a entity or individual or whatever is receiving based on these reporting requirements to what they're actually reporting on their tax returns. And so what this would honestly do, not necessarily from a revenue raising standpoint, the thing that I would focus on is, this would create a level of additional reporting requirements that quite frankly, most of these digital asset businesses don't have the infrastructure in place, and probably can't actually provide the information for these transfers. It creates an additional reporting requirement that might not be able to be fulfilled by some of the smaller actors. Now again, the centralized exchanges, these big businesses that have billions and billions of dollars of revenue can of course abide by these rules. But when you include the definition of digital assets to be so broad, it could have unintended consequences, or maybe they are intended consequences, to have this additional reporting requirement that is very, very hard to satisfy for some actors, come into play. And so, ultimately at the end of the day, the goal is to raise more revenue. That's why these amendments are there in the first place, but the unintended consequences of what it can do to the industry, or again, maybe intended consequences are something that needed to be considered. So there's no, all of these transactions that are over a certain dollar threshold have to be reported, or at least tagged right under the BSA, the Bank Secrecy Act. But that doesn't necessarily mean it goes directly to the IRS, but now, if that were to go to the IRS, it would give them an additional tool to kind of see and track where there are underreporting potentials for crypto actors. But again, I think the additional consequences that come into play will definitely stifle innovation in the United States and will create an added layer of complexity for businesses in the space and $10,000 of crypto is a lot of money, $10,000. But when you're doing it in units or in comparison to BTC or Ethereum, it's really not that much of those assets. It could be, point to BTC right now, or it could be two and a half or maybe three Ethereum, and a lot of investors, a lot of early investors, a lot of businesses that are moving funds from time to time, send transactions in very large multiples of those amounts. What I'm talking about is the amounts on change, the Ethereum or the Bitcoin amount, not necessarily the U.S. dollar amounts . Some people don't really look at the U.S. dollar amount . So again, it creates an additional level of complexity, which might have the unintended, or like I said again, intended consequences of hurting the crypto industry in the United States.

Marie Sapirie 25:42

Even more recently than the reporting proposals on September 13th, the House Ways and Means Committee Democrats proposed amending the wash sale rules in section 1091 and the constructive sale rule in section 1259 to include digital assets. These changes aren't part of the infrastructure bill they're in the $3.5 trillion reconciliation bill. This is another area where there have been discussions about whether and how the rules apply for at least a few years, but the legislative text is new. Could you tell us about the potential impacts of these proposed changes?

Jordan Bass 26:16

Yeah, definitely. So there are definitely a lot of participants in the market who, and the constructive sale rule will apply to them more, so the wash sale rules will be applicable to many more actors, but the constructive sale rule potential change would effectively make it so that some individual actors and some traders can't really hedge their positions as much as they have been because they're treating these tokens, right, to effectively as securities. But as of now, it's personal property and trading properties a lot different than trading securities and that's why some of these rules are not necessarily applicable. So that will have an impact on the hedging aspect of a lot of individuals that are taking these positions on the constructive sales side, but more importantly, because a lot of people are harvesting their tax losses when the crypto markets are maybe in a downswing or even if they bought the local top in the middle of this year or earlier this year, and they're sitting in a Bitcoin position that they purchased at $60,000 and right now it's underwater. At the end of the year, in theory, they're still long-term bullish, just like the same people that are hedging their position might still be long-term bullish, but they want to make sure that they can minimize their tax liability. These people that are still long-term bullish on BTC, or maybe it's a more of like a different sort of token, like another DeFi protocol or it could be a Ethereum or it could be some other token that has utility that they're looking to invest in. And they think the price will appreciate over time. But right now they're sitting in a large unrealized loss position and they want to offset some of the other gains that they had in the year. So they sell that asset and they buy it back immediately, maybe in the same year, maybe in the next year, but within the 30-day period. And they do that because they can harvest the loss, they can reset their tax basis, their adjusted basis in what they're holding, it'll reset their holding period as well. But like I said, they're, long-term bullish so they're still planning to hold long- term. They just want to harvest the loss. If you cannot do that in crypto and that proposal is obviously not taking in theory, wouldn't happen until 2022, so people would still have the ability to do that at the end of the year. If you're doing that a lot of individuals specifically on my side, as a tax practitioner and legal counsel to a lot of clients, engage in that activity, because they're taking advantage of the ability to recognize losses in the space to offset some of the gains they've had either earlier in the year in the space or in other capital activity they've had for the year. So getting rid of that will for sure minimize the ability for individuals to minimize their tax liability at year end in crypto. If they're looking to re invest in that asset, they'll have to wait a period of time. And in the crypto space, of course, that could [be] 30 days, 20 days, 10 days, 60 days, it doesn't really matter, it could be five days, prices could appreciate, 50 to 60, 75 percent or more. So maybe that will cause people to not sell off their assets at year end, because they want to just maintain their position in hopes that the price will appreciate again and get back to where they entered or maybe in excess of that. But what that does for a lot of people, and this is a good time to highlight what happened to a lot of people in 2017 is they had a lot of trading activity throughout the year, and the prices were appreciating all throughout the year. And so November, December comes and there's this crazy bull run. And people are getting 2, 5, 10 X return on their investments in the matter of days or even weeks. And they're selling, they're selling, and then at the end of the year, the price starts to come down a little bit, but they think that the price is going to go back up, but the price has come down significantly. There's been like a 30 or 40 percent draw down from December 15th to December 30th, to December 31st. And they hold. Had they sold, they could recognize some losses and buy back later the next day, but they can't do that anymore. And what happened to a lot of people is they held, they held, they held, they had all these gains that they recognized throughout the year. And then by the time their tax liability became due on April 15th, their portfolio had drawn down significantly to the point where their portfolio value was less than what their tax liability even was, because that's how dynamic this market is. It can change so drastically up or down, that was before a lot of the infrastructure had been built out like it is today. So maybe we won't see as volatile of swings, but we see it all the time. It even happened a couple of weeks ago. So had that person engaged in some harvesting of their tax losses at the year end, but still believed in those projects, like they thought they did, they could have recognized losses to offset the initial gain that they had and minimize the tax liability. If they still were holding onto the assets all the way through the draw down as 30, 40, 60, 75 percent, they still might have been in the situation where they didn't have a portfolio value that was even in excess of their tax liability, but at least their liability would have been brought down. However, now that can't be done so after this year potentially, so that strategy would effectively be moot , but there is some open to interpretation aspect of this, because what is deemed to be substantially identical when we're talking about digital assets. There are certain assets that, there's Bitcoin, but then on the Ethereum blockchain, maybe there's Wrapped Bitcoin. And so are those substantially identical? Probably, but they are different assets. They are on two different blockchains. So maybe you could sell your BTC for Ethereum and then purchase Wrapped BTC within that timeframe, and that isn't considered a washed-out . We don't know. That's where we need further guidance on issues like that. But the wash-sale rules will affect a lot more people in the U.S. than the constructive sale rules for sure. They both are very, very important to keep an eye on and see if that's something that will be finalized and actually put into play .

Marie Sapirie 32:10

Well, thank you Jordan for joining the podcast today.

Jordan Bass 32:11

Thank you so much for having me.

David D. Stewart 32:15

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 will you have for us?

Paige Jones 32:26

Thanks, Dave. In Tax Notes State, Vadim Mahmoudo examines fact patterns involving the liquidation or wind-down of a corporation or a disregarded entity owned by a corporation. Billy Hamilton addresses the saga of an Arizona proposition that imposes a tax increase for education. In Tax Notes International, Stephanie Wu and B. Anthony Billings examine how the subpart F and GILTI regimes apply to U.S. multinational corporations. Claudio Vicinanza and Ignazio La Candia examine Italy’s implementation of the EU directive requiring intermediaries and taxpayers to report cross-border tax planning arrangements. In Featured Analysis, Marie Sapirie provides a list of likely changes that Congress will make as it moves toward a reconciliation bill, she argues that the budget process as it is currently being used only increases the likelihood of churning tax rules, theatrics, and multiple rounds of technical corrections. On the opinions page, the commentary editors in chief of Tax Notes share the topics they hope to see covered this fall in the latest editors wishlist. And now for a closer look at what’s new and noteworthy in our magazines here is Tax Notes Federal Editor in Chief Ariel Greenblum.

Ariel Greenblum 33:52

Thanks, Paige . I'm here with Rob Warren, assistant professor of accounting at the Davis College of Business and Economics at Radford University to discuss the Tax Notes Federal piece he recently coauthored with Timothy Fogarty titled, "More Tax Cops Are Needed to Close the Tax Gap." Welcome to the podcast Rob.

Rob Warren 34:16

Oh thank you, its a pleasure to be here with you and your listeners.

Ariel Greenblum 34:18

To begin, can you give us a brief overview of your article?

Rob Warren 34:22

Well President Biden's proposal to give the IRS 40 billion more dollars over the next 10 years in order to generate an extra $104 billion in tax revenue has brought the issue of the tax gap to the forefront of the political debate. That has generated a lot of controversy on both sides of the aisle. In response, myself and my author, Dr. Fogarty , wrote an article to address four critical questions. Number one, is the IRS underfunded? Number two, is the IRS understaffed? Number three, would giving more money to the IRS be spent efficiently? And probably the biggest question, would extra funding result in extra tax collections? And by the way, the answer to all four is yes.

Ariel Greenblum 35:06

Thank you. Where did the article idea originate from?

Rob Warren 35:09

Well, I spent 25 years with the IRS and retired as an IRS criminal investigator in 2016. But throughout my career, I was a revenue agent, which is a civil auditor. Then I switched to criminal investigation. And then I ended my last two years as a senior analyst in headquarters. And at the IRS, they are the only organization that is tasked with closing what we call the tax gap, which is a difference between what the IRS should collect and does. And so I spent my whole career in one way or another, trying to close the tax gap. So it's an issue close to my heart.

Ariel Greenblum 35:43

Before we let you go, where can listeners find you online?

Rob Warren 35:46

The easiest thing to do is just type in Dr. Rob Warren at Radford University, and my bio page will come up.

Ariel Greenblum 35:53

Thanks for joining us on the podcast Rob.

Rob Warren 35:55

Oh, it's been an honor. Thank you.

Ariel Greenblum 35:56

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

David D. Stewart 36:17

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.