Ireland Mulls Tax Options to Stay Competitive in Global Economy

Ireland has presented a frugal budget for 2026 in the face of uncertainties caused by President Donald Trump's tariff and tax policies. The 15% global minimum tax on corporations and Trump's threats to impose large tariffs on pharmaceutical companies—most of which are US companies headquartered in Ireland—have increased pressure on the country to find ways to remain competitive. With foreign-owned multinationals in Ireland paying the majority of the country's corporation tax, the government is mulling incentives to encourage them to stay. In this episode of Talking Tax, Bloomberg Tax reporter Ryan Hogg discusses some options the government is considering, including an increase in the R&D tax credit. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Taxpayer advocates are keeping close watch on this week's decision to name Social Security Administration Commissioner Frank Bisignano as CEO of the IRS, and have many questions about what it could mean for the agency. Treasury Secretary Scott Bessent said Monday he was creating a new IRS CEO position, and Republicans in Congress seem to be generally supportive, though some said the White House should still name an IRS commissioner nominee. The Treasury Department assured staff in GOP Iowa Sen. Chuck Grassley's office that a commissioner nominee would still be sent to the Senate. At the same time, the Senate Finance Committee voted Wednesday to advance Derek Theurer's nomination to be undersecretary for legislative affairs and Donald Korb's nomination to be IRS chief counsel. That's good news for Pete Sepp —president of the National Taxpayers Union, a taxpayer advocacy group—who is concerned that many of the top IRS positions remained unfilled. Sepp, who sat down with Bloomberg Tax Senior Reporter Chris Cioffi for this episode of Talking Tax, said Congress is right to seek answers about how the CEO job interacts with the commissioner. He said he hoped the CEO position, in the future, would be selected by an IRS oversight board that has been dormant for more than a decade. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Ever since student athletes gained the right to be compensated for use of their image in advertisements and merchandise sales, the money has flooded in, but so have some problems. While the athletes can now be compensated for their name, image, and likeness—or NIL—schools still can't directly pay them for playing, and the NCAA has rejected any notion of "pay-for-play." Instead, athletes can receive compensation when merchandise with their name or number is sold or for showing up in advertisements or social media posts for businesses. But the line between NIL and pay-for-play can get blurry. A business owner who wants to support the team could overpay an athlete in an NIL deal, raising a question: Is it a bona fide business deal? On this week's episode of Talking Tax, University of Kentucky professor Stephen Lusch talks with reporter Caleb Harshberger about how transfer pricing and tax law concepts can help show whether the deals are done at reasonable prices that really reflect the value the student brings. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

About three months have passed since Treasury Secretary Scott Bessent announced that the US, along with its Group of Seven allies, agreed to work on a system that would exempt American companies from parts of the global minimum tax. In that time, the US proposed a technical solution to separate its tax system from the global minimum tax. But other countries have raised concerns about what the US position means for their own tax sovereignty and whether their companies will be left at a competitive disadvantage compared to their American counterparts. In this episode of Talking Tax, Bloomberg Tax reporters Saim Saeed and Lauren Vella hash out these countries' frustrations and discuss the feasibility of coming to an agreement on a "side-by-side" system by Dec. 31, the deadline suggested by the Trump administration. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Big job cuts and reductions in resources at the IRS are liable to prolong disputes over tax bills and force the agency to leave money on the table when cases are finally resolved. More than 170 attorneys have withdrawn from representing the IRS in cases in US Tax Court since Donald Trump became president in January, according to a Bloomberg Tax analysis. Many have quit the IRS altogether amid a major exodus of employees. Some Justice Department attorneys who represented the IRS in tax disputes in federal appeals courts have also left, moves that could impact some of the biggest, most prominent tax-related cases in the courts. The diminished resources suggest it’ll take longer to resolve cases, former attorneys and former IRS and DOJ officials say. The IRS may also be pushed into considering settlements in some cases where perhaps it wouldn’t otherwise. That would mean settling cases on less favorable terms for the agency, and potentially give taxpayers a leg up in dealing with the IRS. In this episode of Talking Tax, Bloomberg Tax senior reporter Michael Rapoport discusses the attorney departures and their implications, as well as attorneys’ frustrations about their jobs and fears about the future that prompted some to leave the IRS. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

President Donald Trump's widespread tariffs are boosting tax dispute risks for companies that are scrambling to understand how to factor the new trade duties into their transfer pricing and tax planning without attracting an audit. Tariffs raise the prices of imported goods, meaning companies importing products from their own affiliates may have to—or want to—adjust the pricing of those transactions to meet transfer pricing rules that require them to treat the deals as though they were done at arm's length, with unrelated parties. The added cost of the tariff will likely knock the pricing for many goods out of that arm's-length range, so companies may have to adjust these prices to stay compliant. Additionally, companies may be able to make adjustments to mitigate the tariff impacts by reducing the price the US entity pays for the good. These adjustments can attract scrutiny, however, from both tax and customs agencies. And growing geopolitical tensions may make it hard for companies to rely on tax dispute resolution mechanisms like mutual agreement procedures. In this episode of the Talking Tax Podcast, Crowe LLP transfer pricing practice leader Sowmya Varadharajan talked with reporter Caleb Harshberger about the choices, and risks, companies are facing. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Tax preparers consider themselves foot soldiers on the front lines of Americans' income tax preparations. They provide advice and file the returns, helping the government collect its revenue and make sure people are paying their fair share. They are also some of the first to warn taxpayers about scams. This group of preparers includes enrolled agents, who are the only federally licensed tax practitioners.  Enrolled agents now are assessing what the recent exodus of thousands of IRS workers and agency leadership means for filing season. They're also watching for guidance for how to implement new policies from the massive 2025 GOP tax law. Bloomberg Tax’s Erin Slowey spoke with Jennifer MacMillan, president of the National Association of Enrolled Agents, about rules related to overtime and tips from that new tax law, the regulation of tax preparers, and what happens next at the IRS as its workforce has been slashed. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Congress is back in session with just a few weeks to reach an agreement before government funding runs out Sept. 30. For IRS watchers, the lack of agreement on how to fund the tax collection agency or whether to extend expiring tax breaks rank among the key issues lawmakers will grapple with over the coming months. In this week’s episode of Talking Tax, Bloomberg Tax reporter Zach C. Cohen and Bloomberg Government reporter Maeve Sheehey preview the government funding fight and potential movement on budget reconciliation bills, and the impact on tax policy and administration. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

As President Donald Trump's tariffs make waves in the world economy, multinational companies are mulling what it could mean for their intangible assets like intellectual property and brand recognition. The vast majority of corporate value comes from intangibles. In 2020, such assets made up 90% of the value of the S&P 500, according to an often-cited study by IP consultant Ocean Tomo—up from up from just 17% in 1975. Tariffs don’t directly levy fees on intangibles, but their value is often embedded into imported products, raising the tariffed price. These intangible assets can also come with a smorgasbord of options for companies to locate IP in countries to best blunt the impacts of tariffs or reduce taxes on their business. On this episode of Talking Tax, Grant Thornton principal Glen Marku talked with reporter Caleb Harshberger about what companies' intangible assets could mean for their tariffs exposure and whether they need to rethink their tax planning. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Big Four accounting firms are racing to integrate next-generation AI technology across their service lines and develop a talent strategy to match the industry's new era. KPMG is focused on making sure it's balancing efficiency gains because of artificial intelligence with long-term workforce development, according to Sandy Torchia, vice chair of talent and culture at KPMG US. The firm has created new learning opportunities for workers to teach them how to use AI to enhance career growth, she said. Like its competitors, KPMG has rolled out new autonomous AI that can accomplish tasks with minimal human intervention. The industry's next generation is taking note. The vast majority of KPMG's US interns expect at least 20% of their work to be automated by AI by the time they start full-time positions, according to the firm's recent survey. Torchia, who is also head of people for KPMG's Americas region, recently stepped into a new role as global co-head of people for KPMG International. She spoke with Bloomberg Tax reporter Jorja Siemons about how KPMG is helping employees adapt to an AI-led future, as well as the state of hybrid work and the CPA pipeline. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.