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The Biden Budget: Build Back Better Again?

David D. Stewart: Welcome to the podcast. I'm David Stewart, editor in chief of Tax Notes Today International. This week: it's not easy being a green book.

On March 28, the Biden administration released its budget for the 2023 fiscal year. The budget looks to restore many of the proposals that were cut during negotiations over Build Back Better Act, as well as introduce some new ideas.

So, what are some of these new proposals, and how is this different from the Build Back Better Act? Tax Notes reporter Jonathan Curry will discuss more about that in just a minute.

Later in the episode, we'll hear from Tax Notes State columnist Tony Santiago discussing his series on the hiring and retention of U.S. tax professionals.

But first, Jonathan, welcome back to the podcast.

Jonathan Curry: Hey Dave, good to be back. I'm turning into a bit of a regular.

David D. Stewart: Yes, you are. Now, I understand you recently spoke with someone about President Biden's budget. Could you tell us about your guest and what you talked about?

Jonathan Curry: Sure. I talked to Rohit Kumar. He is one of the leaders at PwC's Washington National and Tax Services. I think you and our listeners are going to agree that after listening to this that Rohit was the perfect guest to talk through President Biden's latest budget.

He's someone who thoroughly understands the technical aspects of tax policy. He really gets in the weeds. But he also has a very extensive background from working on Capitol Hill for quite some time, including about seven years serving under Senate Minority Leader Mitch McConnell, R-KY.

So, in our conversation we covered not only what you need to know about what was actually in Biden's budget, but also why those policies matter. Or, as you'll see in some cases, why maybe they don't matter so much.

Again, I think you'll see Rohit really is sharp as a tack. If you're anything like me, you're going to walk away from this conversation with a better understanding of what's going on in Washington from both a policy and a political perspective.

David D. Stewart: All right. Let's go to that interview.

Jonathan Curry: Well, Rohit, thank you so much for being here.

Rohit Kumar: Thanks for having me.

Jonathan Curry: So, let's get this out of the way up front. In general, what is a president's budget? It's not a bill, so what's even the point of it?

Rohit Kumar: So, the point of it, it's essentially a wishlist of proposals. And while it almost never, and literally never is enacted as written, it does actually serve as a useful template for establishing what the administration is for, what policies they want to pursue. It's sort of a sense of priorities.

And in some ways it is, to my mind anyway, often I see it as the beginning of a conversation. So, even if the administration isn't going to get exactly what it's asked for in the budget, it's their opening bid in essentially any negotiation that might ensue for at least the next year, if not the duration of the administration.

And I will tell you in my own experience on Capitol Hill, on occasion when we were in negotiations with an administration, I would often use their budget and say, "Hey, here's a proposal that you're for because it's in your budget, that I think I could get support for on my side of the aisle. I'm thinking about a bipartisan negotiation." And so it was a useful menu of options from which to choose.

Jonathan Curry: OK. So it definitely has practical uses. We also have— Treasury puts out its green book alongside this budget. Can you tell us a little bit what the green book is? And most importantly, is it in fact green?

Rohit Kumar: So, the color of the green book, the cover of it, back when it used to be distributed exclusively in paper form, was sometimes green, sometimes blue. Now, we get it digitally, and so the copy I see is black and white on my screen.

The green book is a sort of more granular distillation of the revenue proposals. So, typically tax proposals that are embodied in the administration's budget.

So, like this year, the budget came out a little bit before the green book, a little bit—like by hours, not days. And you looked at the budget and you had like high level sense of what the revenue proposals might be.

But then the green book actually goes into fairly reasonably significant detail, "Here's the proposal. Here's what it means. Here's what the current policy is. Here's why we think it needs to be changed. And then, here's the change that we would propose."

It is not legislative language and it is not in its own enough that you could draft legislative language. There are always lots of details that are unanswered in the green book. But it gives you a general sense, again, like the budget, it gives you a general sense of policy.

And also, it just as importantly serves as a menu of options that in a future negotiation you might pick from, both on the revenue raising side, but also on the tax cut side. So, the green book is not just tax increases, it's not just tax cuts, it's a combination of both.

Jonathan Curry: Yeah. So, it's definitely more than an outline, but it's not a fully fledged legislative document ready to go right off the bat, I see.

So, this year there was an interesting inclusion in President Biden's budget. They were referred to what's called a "deficit-neutral reserve fund." And I'd like to hear you talk a little bit more about this. The status of the Build Back Better Act is kind of in flux right now, a little bit up in the air. And so what was going on with that?

Rohit Kumar: Yeah. So the administration had— It was admittedly a tricky thing to navigate. Because you're right, the House has passed its version of the reconciliation bill, so-called Build Back Better legislation. That bill is pending in the Senate. And I think it's reasonably clear to anyone that's been paying close attention to this, that the version that the House passed is not likely to have sufficient support in the Senate to be sent to the President's desk for signature.

It's probably going to have to be much smaller in its scale and ambit. And so, while the administration is acutely aware of this fact, neither did they want to concede what would or would not be included because this is the object of an active negotiation.

So, they just decided to wave a magic wand, if you will. And say, "We're just going to assume that everything that's in the House passed bill, with the exception of the changes to the state and local tax deduction, the so-called SALT cap, that everything else in the bill ends up being enacted. And we're just going to assume it is a part of the legislative baseline, that thing has already happened," even though it is not happened. And it would not be, I think, controversial to say that it is not going to happen, at least not in the form that passed the House. But the administration, I think understandably, did not want to signal where the negotiation stood, or what they might be willing to dump overboard and what they would cling to with every last dying breath.

And so, they just said, "We're just going to assume all of these things are true. And then we will propose additional policies on top of that." So, for example, the administration had proposed in the past and has reproposed a 28 percent corporate headline rate. Well, there's not even a one point increase in the headline rate in the House passed bill.

So, if you assume the House bill becomes law with a 21 percent headline corporate rate, then you've got a seven point rate increase that's proposed in the budget. But, for example, some of the international changes that the budget proposes are hypothetically built upon what the House has passed.

And so, the additional revenue you get from these international changes is less than if measured against the laws that exist today, because they are assuming a change in law that has not yet happened. And so, at some level I'm very sympathetic to the conundrum that they face, which is, "What do we do about this pending legislative matter? And we don't want to destabilize the negotiations by taking a position in advance of those negotiations reaching a conclusion." On the other hand, at some level, the whole budget, or at least the revenue piece of the budget is built upon a fiction, and a fiction that we know is not likely to become reality at any point in the foreseeable future.

Jonathan Curry: Yeah. So a little bit of damned if they do, damned if they don't kind situation they find themselves in there.

So this is [President] Biden's second budget. Within this new budget, there were a couple of big new tax proposals that they specifically highlighted. One of them was the billionaires minimum income tax, as well as the undertaxed profits rule (UTPR). On the billionaires minimum income tax, what do you make of this? Is this going anywhere?

They made a big to-do about it. They announced it over the weekend before they even released the budget, there was a lot of excitement about it. Does it even have Senator [Joe] Manchin's, D-W.Va, stamp of approval yet? Where do you see things going with this?

Rohit Kumar: No. So, I don't think this is going anywhere anytime soon. And Senator Manchin has already come out publicly and said he is not supportive of wealth tax style proposals. So, near term it's not going anywhere, but it is meaningful to me in the sense that, this is an idea that's been floating around for a while.

Chairman [Ron] Wyden, Chairman of the Senate Finance Committee, democratic senator from the state of Oregon, has been a proponent of a wealth tax for some time now. But he had sort of been not alone, alone, but relatively alone in that posture.

And then to have the administration adopt, not exactly his proposal, but the same kind of concept that we're going to tax based on wealth not just on income, is to me a meaningful move. And it is to me a signal of a broader, longer conversation about wealth taxes. And what I've been saying to others when asked is, "What this tells me is that this conversation is not going away. This is not a flash in the pan event that you can ignore and is going to go away. This is a conversation that will continue."

Now, there are all sorts of questions about the administerability of said proposal. What do you do with hard-to-value assets? What do you do with losses? If you're going to tax unrealized gains, are you going to provide a deduction for unrealized losses? That would not be without controversy or complication.

And then there are even broader, almost like esoteric questions as to whether a wealth tax would even be constitutional. A question upon which there is substantial disagreement in which would only ultimately be resolved by going to the courts. And in this case, probably the Supreme Court, because this would be such a novel concept of tax policy. And whether it fits with the 16th amendment or not is very much in question.

I actually think if you are an opponent of wealth taxes, either because you would be subject to them, or you just think they're a bad idea, the current Supreme Court might be as good as any in terms of testing the proposition. Because it just strikes me that this construct of the Supreme Court, it strikes me as unlikely to be willing to entertain novel interpretations of the 16th amendment.

Now, that doesn't mean it's going to happen in time for this version of the court to adjudicate the question. But I think this is a conversation that will continue. The technical administerability questions over time could probably be resolved well enough for government work.

The constitutional questions are of course, esoteric at the moment. But if this actually ever got legs and got enacted in the law, I would well imagine that this would be challenged. And then remains to be seen what the court, as it exists at the time this challenge is happening, thinks about this question.

Jonathan Curry: Yeah. That would be interesting to watch for sure.

Another big item in Biden's budget was the undertaxed profits rule. This was a replacement to what they had proposed last year. Can you talk a little bit about what the purpose of this is, why they introduced it now, and then where things stand on that?

Rohit Kumar: Yeah. So, this is interesting because it has a lot of intersection and relevance to the negotiations that have been going on for a while now, dating even back to the Trump administration at the OECD over so-called "pillar 1 and pillar 2 model rules." And the undertaxed profits rule is in the province of pillar 2, which is the negotiation over should there be some minimum level of tax that every company pays in every country in which it has operations?

So, right now the U.S. is the only country in the world that has a minimum tax on the active foreign earnings of its headquartered multinationals. But that minimum tax at 13.125 percent, because why wouldn't it be? It's measured on an overall basis. So, as long as you're paying 13.125, I'm simplifying, there's a lot of detail here that we can't get into.

But broadly speaking, as long as you're paying 13.125 on an overall basis across all your foreign earnings, then you're not subject to an additional top up tax in the United States. And we are the only country in the world that has such a tax, and have had it since 2017 when it was enacted as a part of the Tax Cuts and Jobs Act. And so, the negotiation here is, well, every country ought to have a similar style regime at 15 [percent], not 13.125 and it ought to be measured on a country by country basis.

And so, there are model rules that were published, the most recent iteration was published in December of 2021. And as a part of that, what we discovered is, this 15 percent minimum tax applies not only to the foreign countries in which a multinational is operating, but also in the home country in which it's operating.

So, if you're a U.S. headquartered multinational, in addition to paying 15 percent in France, the U.K., Singapore, or wherever, you have to be paying at least 15 percent on an effective rate basis here in the United States. And in the ordinary course, you might think, "Well, that's not that hard. The headline rate is 21. You've got state and local taxes on top of that. So, being at 15 is not that difficult."

But given the quirks of the way in which the OECD rules account for deferred tax assets, it's actually not that hard for a U.S. company to be below 15 using OECD accounting principles in the U.S. And if that happened, then that U.S. income would be undertaxed, as the undertaxed profits rule would apply and would allow a foreign government to assess additional tax against the foreign subsidiary of U.S. multinational to get them up to that 15 percent rate in the U.S.

So, this is a province of the model rules. And if other countries actually adopt these rules in their own national law, that remains a little bit in question. It potentially exposes U.S. multinationals to additional top-up tax in all the countries in which they're operating. And so, it naturally would follow, well, if other countries are going to do this to U.S. headquartered multinationals, then the U.S. ought to be able to do the same to foreign headquartered multinationals that are operating in the United States.

So, that is the basic of the UTPR proposal, which is, "If other countries are going to do it, then we get to do it as well." And indeed in the proposal, it is clear that the administration is not proposing this as something we would do automatically, but rather this is something we would do only if other countries did the same. So, it sort of triggered, and this is, again, you can get away with this in a budget proposal. How you would draft this is a little bit more complicated, but essentially it's like, "If other people do it, then we will do it as well."

Jonathan Curry: Now, there's been an interesting development on pillar 2 recently, do you want to go into that?

Rohit Kumar: Yeah. So, one of the key features of this pillar 2 regime is, these are model rules adopted by the OECD and endorsed by the inclusive framework, which is 130 plus countries. But as one of my colleagues, Pat Brown, likes to remind me, "The OECD does not have an army. They cannot impose this on the member states."

And indeed the OECD model rules say, "The whole thing is entirely voluntary. If you want to adopt a minimum tax regime, you can, you don't have to, but if you do, here is a model set of rules that we think would make sense. That if you're going to adopt it, this is how you should do it." So, that's a model set of rules, but with no enforcement mechanism, a political commitment, maybe, but no ability to enforce.

So now, we have to start getting into various countries making changes to their own national law. Well, in the EU, for countries to adopt these model rules into their national law, they need the blessing of an EU-wide directive. And that blessing has to be adopted unanimously by EU member states. So, the EU is a little bit like Democrats in the Senate: they need all members to vote yes, in order to have the votes to enact a proposal.

Jonathan Curry: That's pretty hard to get everybody on board, isn't it?

Rohit Kumar: As we've seen, it's very hard to get 50 Senate Democrats to agree, and they are all of the same party and live in the same country. You are now asking 27 different nations to adopt a directive that they should all do the same thing on the same timeline. And not surprisingly, that has proven quite challenging.

France has the EU Presidency at the moment. They have it through for the first half of this year. They have tried now twice to get unanimity amongst EU member states and have failed twice. Most recently on April 5, with Poland vetoing or objecting, and effectively vetoing the directive. Which now really calls into question the timing of EU adoption of a directive, and then subsequent adoption and national law.

And depending on how long it takes to get unanimity, to me at least starts to call into question, not only when, but if. And the reason I say if is because, if the last two years have taught us nothing, is that the world is a very unpredictable place and outlier black swan events do in fact happen. They don't happen regularly, but they don't happen never.

And if it's not for another 12 or 18 months before the EU gets back around to considering a directive, it's entirely possible that intervening events, both domestically in the various countries and internationally, there's a war happening in Europe right now, that those things might get in the way of getting the unanimity that would be required.

And so, as we look at what's happening in the EU and the difficulty that they're having in getting unanimity, you then come back across the pond to the United States and you start to ask the question, "Well, if the U.S. is going to try to adopt something that is pillar 2 model rules inspired, should the U.S. be adopting that immediately? Should the U.S. wait to see if other countries are actually going to do this? Or if we're going to make changes to a U.S. law, just like the administration did in its UTPR proposal, should this be triggered on adoption by the G-7, India, China?" Pick a list of countries that you think matter.

But, should we find some way that U.S. changes are done in lockstep with other countries changes, or do we race ahead and go with a Field of Dreams strategy? Like, "If we build it, they will come." That's obviously a little risky because if you build it and they don't come, you have put U.S. headquartered multinationals at a competitive disadvantage. And opponents of the Field of Dreams strategy would point out, "We did build it in 2017 when the U.S. adopted its GILTI regime, no one has yet come. And so, there's no reason to think that making that GILTI regime even more onerous will in any way inspire followers who have not yet shown up."

Jonathan Curry: I see. So it definitely can get messy. You don't sound especially optimistic, at least for the immediate future.

Rohit Kumar: Yeah. Jonathan, part of it is my experience on Capitol Hill, and I have more experience with this than I would like. But when an elected official has voted no twice on something, and Poland has now voted no twice. My experience is it is very difficult to get a twice-no-voter to convert to a yes without some very public and reasonably significant concession. And I just don't know what that looks like in this context.

Jonathan Curry: So, a lot of eyes are going to be on Poland. They're kind of like the Manchin of the EU it seems.

Rohit Kumar: At the moment, yes.

Jonathan Curry: So, back to the broader budget. Obviously, this isn't Biden's first budget. How much of this have we seen already? And do these proposals that are still in there that we haven't seen action on, do they still matter?

Rohit Kumar: So, not much of it is new. The undertaxed profits rule is new. The wealth tax on people, it's called a billionaires wealth tax, but it really applies if you have more than $100 million of annual income. Still a very, very narrow slice of the population to be clear.

So, those are the only things that struck me as really new and breaking out new terrain. The rest of it is mostly a redoubling down on previous proposals. And even though they weren't enacted and aren't likely to be enacted, my experience with administrations and budget proposals is once they make a budget proposal in their first budget, those tend to persist throughout the duration of the presidency.

And if there's a second term, even into the second term of the presidency. Because if you drop them, even if you've reached the conclusion that there is no chance on God's green earth that the Congress is going to adopt these proposals. Dropping them in some ways is more significant than just persisting and including them.

Because dropping them means you've conceded that, either this isn't going to happen or that you think it was not a good idea in the first place, and you now no longer support that proposal. So, it's actually quite rare in my experience for budget proposals, unless they've been enacted, and then it doesn't make sense to repropose them.

But for unenacted budget proposals to not continue to appear in the budget— Because it's more like a statement of principles or a statement of values. And even though Congress might not agree with your principles or values, it doesn't mean you no longer adhere to them.

Jonathan Curry: Another thing, too, in the budget, it sort of struck me as interesting that deficit reduction is such a boldly stated objective. I saw that his [President Biden's] budget is aiming to reduce the deficit by $1 trillion over the next decade. Why do you think that's such an emphasis here? And is that indeed unusual?

Rohit Kumar: So, it's not terribly unusual. Lots of administrations, Republican and Democrat alike, over the course of history have given a head nod to deficit reduction. We have a $28 trillion national debt, at some point we're going to have to reconcile the books. It's not clear when, but it's unlikely that we can persist on this path forever.

But right now in this political moment, I think there are maybe two things happening. One is, there is a lot of concern about inflation. And deficit reducing policies, fiscally contractionary policies, and deficit reduction would be fiscally contractionary, are one way to signal we're taking inflation seriously and we're going to reduce the deficit. And that will have a salutatory effect on inflation.

That's a political talking point. Whether it actually means that in the real world, it depends greatly on the details of the policies and the timing of the policies being pursued. And then I think a little bit, it might be in response to Senator Manchin, who is obviously one of the critical votes in the Senate for a reconciliation bill.

And he has been very public with his concerns about the size of the debt and the deficit, and the desire for deficit reduction. And indeed desire for the reconciliation bill should want to emerge from the Senate to be a deficit reducing bill. And so I think it's a little bit of a head nod to one of the critical votes in the Senate.

Jonathan Curry: Now, politically, do you think that there's any appetite, at least among Democrats, for deficit reduction?

In the past I've talked with democratic tax activists, and they've sometimes described deficit reduction as leaving money on the table. It's never fun to have to raise taxes on people typically, we have to bite the bullet to do that and then we don't even get to spend the money that we're raising. It's usually not a very exciting concept.

Do you think that Democrats could actually unify behind this idea of raising money that they don't get to spend?

Rohit Kumar: So, I think if left to their own devices, as I think about there are 535 members of the House and Senate. My instinct is there is only one, Senator Manchin, who is actively in favor of raising taxes for the purpose of deficit reduction. The Republicans generally don't want to raise taxes, or if they do it's to pay for other tax cuts.

So, it's sort of revenue neutral. And then I think the vast majority, if not all of Senator Manchin's democratic colleagues, are to some degree willing to raise taxes. But as you pointed out, for the purposes of them raising money to spend on—pick a spending program that is popular. And so, I think in a state of nature as it were, there are not many, maybe only one vote for raising taxes for deficit reduction.

But in the current political climate and environment where Senator Manchin represents a necessary vote to get a reconciliation bill out of the Senate, back to the House, and then to the president's desk, is it possible that his democratic colleagues would tolerate some deficit reduction as a part of a broader exercise to advance the reconciliation bill? Yeah, I think it is possible that they would tolerate.

Whether they would tolerate it to the level that he has suggested, i.e., deficit reduction that is— Or offsets that are two-X to spending. So, if it's a $500 billion spending bill, $1 trillion of offsets, so that you are reducing the deficit by the equal amount of spend. That I'm a little bit more skeptical about. On the other hand, if that is the necessary element to get his vote, maybe. But that will be, to your point, that will be a difficult pill for many to swallow.

Jonathan Curry: All right. Well, Rohit, my last question for you.

So, last year when the budget came out, I remember Democrats, they controlled the White House, they had majorities in Congress. They had just finished banding together to pass the big American Rescue Plan Act. And then Biden now put out a budget with all those ambitious proposals in it. And I'm not going to lie, when that happened, it kind of struck me that we gearing up for a democratic version of the TCJA (Tax Cuts and Jobs Act) with their own Build Back Better Act.

And it seemed to me that it's inevitable that something would happen. But then all last year, it kind of ended in December but nothing did happen.

So, do you have any sense that this budget does inform what we might see being enacted this year? Or is it really just more of a long-term conversation starter?

Rohit Kumar: I think it is more of a long-term conversation starter. I would be a little bit, maybe more than a little bit, surprised to see any of the new elements in the president's FY23 budget work their way into the pending reconciliation measure.

I think the reconciliation bill, if one were to emerge, and that is obviously far from certain, will be ultimately populated by proposals that are already on the table, or that were on the table before the budget was released. So, the revenue raisers will be bounded by what was in the House bill. The spending policies will be bounded by what was in the House bill. It will probably be less than what was in the House bill on both sides of the ledger.

But I would be a little bit surprised to see large new proposals, around the edges, around the margins, maybe something small that I'm not paying attention to, perhaps. But like these big new starts in the budget, I don't think those find a home in a reconciliation bill, if a reconciliation bill is even to emerge.

Jonathan Curry: Rohit, thank you so much for joining us. It's been a pleasure having you here, and it's been very illuminating.

Rohit Kumar: Thanks for having me.

David D. 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 will you have for us?

Paige Jones: Thanks, Dave. In Tax Notes Federal, Mindy Herzfeld explores whether and how the OECD's pillars can be repurposed to include a global minimum tax on billionaires. Paige Anderson explores whether real estate investment trust can provide and profit from providing electric vehicle charging station services. In Tax Notes State, four seasoned state and local tax veterans offer their take on the recent ruling on Maryland's digital advertising tax. The Tax Notes State advisory board discusses Supreme Court Justice Stephen Breyer's imprint on state tax and what his retirement will mean to the SALT community. In Tax Notes International, Andrew Velarde writes that the Biden administration wants to drop the BEAT and replace it with pillar 2. Charlotte Tolman and Michael Molenaars discuss the European Commission's proposed directive to target the misuse of shell companies and its potential impact on Dutch holding companies. On the Opinions page, the Tax Notes commentary editors share the topics they hope to see covered this spring, like remote work, environmental taxation, and the tax concerns of partnerships.

And now, for a closer look at what's new and noteworthy in our magazines, here's Tax Notes State Editor in Chief Jéanne Rauch-Zender.

Jéanne Rauch-Zender: Thank you, Paige. I'm here with Tony Santiago, founder and president of TaxSearch. Welcome to the podcast Tony.

Tony Santiago: It's a pleasure. I'm looking forward to the discussion here.

Jéanne Rauch-Zender: Thank you. I am very excited to launch your column Tax Pulse. The first article, Tax Hiring Outlook 2022, is one of a five part series in which you review key factors that influence the hiring and retention of U.S. tax professionals. Would you tell us a bit about the first article and what's to come with a remaining series?

Tony Santiago: The first article is simply to lay a foundation of what some of the major trends we see that will be impacting U.S. tax recruitment, retention, and development of key tax professionals this year.

The follow-up articles will go into much more detail on these major trends. And we will actually start to lay out some of the ideas and thoughts on how to mitigate these impacts or leverage them in a positive way, shall we say, going forward.

Jéanne Rauch-Zender: I'm very excited for the continued series. In your article you write, "U.S.-focused tax expertise can only be described as a captive labor pool. U.S. tax laws and regulations are so unique that we are unable to import tax resources or recruit tax professionals from other countries without significant training. Because of the uniqueness of the U.S. tax code, outsourcing to foreign tax service providers poses similar challenges." Would you explain this a little bit?

Tony Santiago: Yeah. Ironically, just this morning, I was on the phone with the CFO of a major company discussing these points. He was a little bit confused at first by the statement that I made, and then later on, totally recognized why we are not in that position to be able to tap into talent outside the U.S., or import workers, or export the work.

So, we are really caught in a situation where the uniqueness of the U.S. tax code is driven so much on a direct tax basis, but also does have indirect tax basis, is in conflict with most other taxing jurisdiction. So a VAT, GST tax person from APAC (Asia-Pacific) or EMEA (Europe, the Middle East and Africa) really will have little value here in the U.S. with our current direct tax, income tax structure.

And that causes us a unique element of a limited supply, especially when compounded with the demographics of the aging population within the U.S. tax practice. As we'll see later in the articles, this will be brought out and connected the dots between the different trends that we're dealing with, which will increase the impact.

Jéanne Rauch-Zender: Excellent. Very exciting, very insightful article. I'm really excited for the continued discussion and to be working together. Before I let you go, where can listeners find you online?

Tony Santiago: LinkedIn, I have a profile there. Our companies have pages. We have three entities. Our executive search group is TaxSearch, which most U.S. tax professionals are familiar with. We've been in business for now 39 years. Additionally, we have TaxForce, which is a new offering in the last 10 years that we've brought to the table. So, there's information there on interim staffing solutions. And last, but not least, there's TaxTalent, where most of our thought leadership content has been put out for decades. There you'll find information on the new aging demographic trends that we have. You'll find information on compensation trends, higher salary inflation and such we're going to talk about in this article, and many other topics that are relevant to the tax profession.

Jéanne Rauch-Zender: Absolutely. Thank you so much for joining me, Tony. It's been a real pleasure.

Tony Santiago: Pleasure is all mine. Thank you, Jéanne. Take care.

Jéanne Rauch-Zender: You too. You can find Tony's column online at And be sure to subscribe to our new YouTube channel, Tax Notes, for more in-depth discussions on what's and noteworthy. Again, that's Tax Notes with an S. Back to you, Dave.

David D. 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 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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