David D. Stewart: Welcome to the podcast. I’m David Stewart, editor in chief of Tax Notes Today International. This week: tax and ESG.
Environmental, social, and governance performance, also known as ESG, has become increasingly important. Investors, employees, and the public are interested in what companies’ ESG activities look like and the transparency ESG reporting provides.
As multinationals broaden their ESG reporting, there have also been calls for expanded transparency in tax reporting, especially as it relates to the social metric of ESG. So, what does the intersection of tax and ESG look like? And what kind of ramifications would increased tax reporting transparency have? Tax Notes contributing editor Nana Ama Sarfo will discuss more about that in a minute.
Later in the episode, we’ll have Tax Notes State columnist Steve Wlodychack discuss his article on recent state passthrough entity tax legislation.
But first, Ama, welcome back to the podcast.
Nana Ama Sarfo: Dave, thank you so much for having me back.
David D. Stewart: Now, I understand you recently spoke with someone about tax reporting and ESG. Could you tell us about your guest and what you talked about?
Nana Ama Sarfo: Yes, so I spoke with Eelco van der Enden, who is the new CEO of the Global Reporting Initiative (GRI), and GRI is an international ESG standard setting organization. It actually produces the world’s most widely used ESG reporting standards.
Eelco, who took his post in January, is a very exciting choice for CEO because he’s a dyed-in-the-wool tax practitioner. He previously was a tax partner at PwC, and so he helped write GRI’s reporting standard for tax, which is a public country-by-country reporting standard.
We spoke a bit about his vision for GRI, and GRI approaches reporting from a stakeholder economic vision, which is that multinationals should be accountable to all stakeholders, not just investors, but also their employees and the communities in which they operate.
He discussed why public tax disclosures are so important in a stakeholder economic model, and also trends he’s seeing in the tax reporting space like multinationals greening their tax reporting. He also talked about what is at stake for multinationals if they fail to be transparent about their tax activity, and in doing so, kind of lose the public narrative.
David D. Stewart: All right. Let’s go to that interview.
Nana Ama Sarfo: Eelco, thank you so much for joining us on the podcast.
Eelco van der Enden: Thank you … [for] having me.
Nana Ama Sarfo: Now, can you describe for our listeners, those who aren’t familiar with the Global Reporting Initiative, a little background about its sustainability reporting framework?
Eelco van der Enden: GRI was founded in 1997 in the United States to provide businesses with a framework of reporting standards on social and environmental topics. In those days where there was, of course, the big oil spill in Alaska, there was social unrest, and what financial reporting standards, international accounting [and] financial accounting standards, did not provide for was with a clear framework to report one's social and environmental endeavors in such a way that it would create comparable data and comparable data not only for investors, but for wider society.
That for GRI is extremely important because our purpose is basically to provide support for impact reporting, to have an open and transparent discussion on topics that affect society as a whole. So it's climate, it’s socioeconomic cohesion, and all the topics that are aligned.
Why do we think this is important? Because the world does not only exist for capital markets and investors themselves, but it also exists for a broader humanity and humankind as it is.
So what GRI typically does and what GRI provides is not only what financial reporting standards do, is what the effects are of environmental and social topics on the value creation of the reporting entity. No? GRI provides a framework for what the effects are of business endeavors in pursuing their strategies on the environment and on society as a whole.
Now, what do we see in development when it comes to sustainability reporting as such because ESG and sustainability became like household definitions of late. And there is this discussion around and about the alphabet soup that there are so many organizations dealing with sustainability and ESG that there is no clear picture anymore because it's muddled with these many, many acronyms.
Well, in fact, let me demystify the alphabet soup when it comes to sustainability reporting. There are only two standard setters that deal with ESG as a standard. That is SASB (Sustainability Accounting Standards Board), that now has been incorporated in the ISSB, the International Sustainability Standards Board, which is a sister organization of the International Accounting Standards Board under the umbrella of the IFRS (International Financial Reporting Standards) foundation on one side.
And on the other side, you have the European Financial Reporting Advisory Group, EFRAG, that is responsible for setting ESG standards, sustainability standards for Europe, mandatory sustainability standards. And they have this co-creation agreement with GRI.
What is the big difference between them? And that is extremely important to know, especially when it also comes to tax, which is an S social topic in ESG. What are the major differences between these two initiatives on sustainability reporting? Well, first of all, ISSB is about financial reporting. It's about financial materiality. The information, the objective, the public is investors. It is intended for investors and shareholders. So it drives financial information, the enterprise value reporting of the reporting entity.
What is the European initiative? What is GRI all about? It is what we call, “double materiality.” So it's not the financial effects of the reporting entity. No, it is its effect on climate and society as such, which has a different lens, but that's logic because they have a different audience they take care of. So GRI Europe is a wider audience society, whereas the objective of ISSB or SASB is investors.
Are these two competing forces? No, they are not competing forces. They strengthen each other. They should, and we should drive towards a corporate reporting environment on a global scale that is based on two pillars. And then you have a complete picture where you have the financial interests and societal interest being reported on equal footing, whereby and only then, you will be able to claim that we are moving from a shareholder capitalistic centric model to a stakeholder capitalistic centric model.
So what do I mean by that? And I don't like the word “capitalistic.” I like the word a “stakeholder-centric economic model,” because that's where we are moving to. If you do not have the two-pillar approach with financial and sustainability reporting at equal footing and equally important, you cannot speak of a stakeholder-centric economic model.
Everyone agrees that financial data is very important for investors. Hence the introduction of mandatory, international accounting standards for listed companies to provide investors with comparable data. It was in those days of shareholder-centric model, whereby the idea was that the sole responsibility of business is making profit on behalf of its shareholder. It is absolutely completely logic to introduce mandatory financial reporting to enable these investors to make proper validated decisions on comparable data.
So if we now claim, as recently Larry Fink of BlackRock did, if we now claim that we have to move towards stakeholder-centric economic model, and not only BlackRock is claiming that, but also the World Economic Forum and International Business Council, then it will be very weird not to have a reporting standard that is there to feed the needs of society, the society that the stakeholder-centric economic model tries to support.
So you can't have a stakeholder model without sustainability reporting on behalf of society. So if you would stick only to reporting on behalf of investors, you do only half that you have to do. So if reporting can be compared as a coin, these are the two sides: the financial reporting and the sustainability reporting. And that's exactly the second part, the sustainability reporting, that GRI does. And it has done so over the past couple of years quite successfully.
Nana Ama Sarfo: Now, as you are well versed with, about five years ago the GRI board decided to create a public reporting framework for tax, which is called the GRI 207 standard. And GRI 207 is important because it is the first global reporting standard for country-by-country tax transparency. You co-wrote that standard when you were a partner at PwC, so I’m hoping that you can walk us through that process.
First, why did the GRI board decide that tax is important for ESG reporting? And what are some of the most important elements of that standard, and why were they included?
Eelco van der Enden: First of all, the initiative to draft a standard on tax was taken by U.S. private equity firms. So it was not NGOs like Tax Justice or Fair Tax Mark or whatever, what some people think. No. It was U.S. investors that reached out to GRI to say that they wanted to see more detailed information on tax, because it told them something about the risk appetite, about the quality of the profits themselves, and about the link between the sustainability policy companies have, and tax, whether there was a link in, let's call it the management of tax behavior when it comes to social topics.
So, there were various reasons why these investors were interested in getting more information out there. The board of GRI, or I have to say the standards board of GRI, which is the organization within GRI that takes care of the standard setting and development processes and the maintenance process of the standards, this is hard capital-intensive work by the way– they decided to put together a community of specialists that became the tax technical committee. And I was kindly invited to join that as a representative of intermediates, in this case, the big audit firms.
So, we started to discuss some topics that we thought would be interesting for a multi-stakeholder community to take notice of. And many said that with such a sensitive topic as tax, this would not be possible, but they were people out of the tax communities that said that. In fact, one of the issues is that I think that many tax people, oversensitivize, if that's English, tax as a topic. It's not that sensitive. And in fact, after a year and a half, we were done, which is quite fast, where all participants in the committee signed off. And then the first draft was sent for public consultation.
So, 2019 in December we came out with it and the official launch was at the London Stock Exchange in January 2020. And then we were rather surprised by the voluntarily uptake of many, many large multinationals to indeed embrace this standard.
And why is this standard then so liked? Because there you have it again – it provides a platform to provide comparable data. That's important to investors. That's important to society; that they can compare likes for like.
And as GRI is the world's largest sustainability standard setter, it has been endorsed by the OECD, by the United Nations. Why should I not use the GRI 207 standard when I use GRI already for all the other things that I'm reporting? And there’s more than 10,000 companies that use GRI. So the pickup has been quite high already. Whereas the only year that we basically ask, if you are a GRI reporter, please start [using] 207 from 2021, which was last year, but already before many started to use them.
Also, when you look at or have discussions with boardrooms, with audit committees, with CFOs, because it is a real standard, there has been this huge due process behind it with this multi-stakeholder environment of professionals out of various constituencies that have been drafting this.
Nana Ama Sarfo: Fantastic. I think that overview was so fascinating to hear 1) the background behind how this standard started. I didn't realize that U.S. private equity firms had a huge hand in this. But then also to hear that it moved from that sector into a more multidisciplinary conversation, I think is very interesting and very helpful to know.
Now, as you had mentioned, the GRI standards generally and 207 have witnessed a really great adoption, but I think we also have to look at the other side of the coin, which is that the idea that corporations have this public responsibility to share their tax data is not universally accepted.
As you had mentioned, over the years, we've seen some major multinationals decide to publicly share their tax data, but then others have been reluctant, citing business confidentiality, as you had also mentioned. So, my question for you is what is at stake here if corporations are not transparent about their tax activity?
Eelco van der Enden: Tax is just another topic. Let us be perfectly honest. With all introductions of new reporting standards, you will have people that will come with the evergreens of why not to report. There are always people that say, “Well, the burden is too heavy. We don't like it, blah, blah, blah.” So why do I think that is not entirely true? And why would some organizations try to push back on this or don't want to report on it? And there can be various reasons.
There are also, by the way, very legitimate reasons. In some countries you are not allowed to disclose too much information on certain contracts. We know this from China, we know this from Ivory Coast, so you just cannot publish it. But you have to look at this through a broader business strategy lens. If you are a large business and you have an ESG policy and your ESG policy is basically the engine that helps you to commit to achieving the sustainable development goals that like everyone in the world signed up to and all large business signed up to, so then how do you do it? We look more at the environment. We look more at social topics and we look more at governance.
So if you have a policy around that, then how does tax interact with that? So if you want to be more transparent beyond what you are legally obliged to do in the financial reporting, and you have endorsed, or you use SASB standards or GRI standards, then why wouldn't you report on tax?
Because tax is an ESG metric, not because I say so or because the World Economic Forum said so in their 2020 report, and one of the 22 core metrics is to report on is tax. So what would then be the reason? And what type of information would yield more business secrets than, for example, the technical explanations on how you reduce your carbon emissions, which is at the core of your production processes?
And also taking into account that tax data with a bit of effort, can be extracted from annual financial reports filed at Chambers of Commerce, you can do deep dive in unstructured data, et cetera, et cetera. So why, if you have this vision on sustainability and stakeholder centric model, why would you exclude tax? You know that society's interested in tax and tax positions?
I mean, we are ending the COVID-19 pandemic that has cost states hundreds and trillions of millions of dollars. We have seen, of course before the large financial crisis, we see that there are some big things to cover. We have issues on climate. We have large demographic issues. This all needs to be taken care of by civil society and by governments, for which they need, of course, tax.
They want to see what contributions are by businesses on behalf of society, and not on a consolidated basis, but also basically in the communities where you operate. And you do not only provide that information because Tax Justice or Oxfam is shouting off the roofs that it's not fair or whatever. No. You want to share that information because your suppliers, your clients, the communities you operate in, your employees, they are interested in that information.
And then what is so sensitive not to provide that data? To some, there is a very deep, politically rooted aversion to provide more than beyond that what is legally necessary. I respect that because if that's your view on how things should work, then that's your view on how things should work. I'm not trying to say what morals of others should be, but if you do not have this political conviction that providing data on tax is wrong by itself, then you need to have very good arguments why not to provide that information.
Because when it comes to business secrets, the secret basically you deal with in tax mostly is why you are paying what you pay, and not so much on secret formulas or competitive price mechanisms.
Nana Ama Sarfo: Well, I think you raised some really, really great questions as to why multinationals might oppose this and why their opposition might not make a lot of sense.
Now, I do think that the current debate over public tax disclosures feeds into a much larger discussion about the kind of economic system we should have, which is a point that you raised earlier. So should we have a stakeholder-centric economic system or a shareholder-centric economic system, which right now seems to be the predominant model. So my question for you is: is tax transparency more or less important in one model versus the other?
Eelco van der Enden: I think in both models it is important. And let's not forget that by far the majority of multinational companies play an extremely fair tax game. Absolutely. They have nothing to hide. There is nothing to hide. I mean, they are a totally fair contributor to society with jobs, investments, and their tax contributions. In both models, it is important, and I call that a “neoliberal tax paradox.”
By not paying tax as an idea to maximize your profit over time, you will see a lot of value destruction of your organization since the environment you operate in will not be able to support your business. So it's shortsighted. And that's why I like the 207 standard, because it clearly shows what a stakeholder-centric economic model means and what society does for a company and what a company does for society. They are two sides of the same coin.
Nana Ama Sarfo: Now, you had mentioned that most multinationals are operating above board, right? They're not engaging in serious tax evasion, avoidance, or anything like that.
Given that, why do you think that there is this persistence to hold up tax as this precious thing that cannot be revealed that it's best for the tax community to determine what should be disclosed instead of just adhering to these common ESG standards?
Eelco van der Enden: The reasons we hear are sometimes simple and very operational and very down to Earth. Sometimes it’s not that people don't want to do it, but they say, “We just do not have the capacities to start this up. We do not have our systems in place to attract that information and process it easily. It will mean an investment and I am already understaffed.” So it is also sometimes an operational thing.
So then when it comes to year-end closing, there is a merger, there is an acquisition, there is some case or an investigation by tax administrations. These departments are stretched and stressed and then think, “Oh my God, then I also need to have a GRI 207 report to publish. Where the hell do I find people to do it?”
That is really a reason we hear quite often, which then again, of course, that is an interest of investors. It tells you something about the level and the quality of your internal controls and the efficiency of how you manage your organization. But it is a first step.
The second one we sometimes hear is that people just have no clue that it does exist, and they don't understand the concept of sustainability reporting, financial reporting, financial materiality, double materiality. Those concepts are not very well known in the tax community, for which you cannot blame them because they're mostly specialists that understand and do a great job in following the law.
This is something a bit more holistic, perhaps not that concrete, there is not a lot of interaction between civil society and the tax community. That's also due to the very technical nature of tax. So that is one.
And the other one is that some companies just don't want to disclose because they are afraid that there will be a lot of turmoil in the market or by the public when they provide information. Well, I can't mention any names that all those companies that are reporting under 207, they all had to take the first step and like, “Oh my God, what’s going to happen when we go live?” And now, not one of them got negative comments on the reports themselves or were crucified in the press for publishing the information.
There were companies that had discussions with some NGOs on whether it was sound or not sound business to have a hub on the Virgin Islands or that was indeed aggressive tax explaining, but at least they had a debate on facts and not on perception.
So this fear element for many appear to be completely untrue, and now they love publishing it and doing it, especially the tax departments. They love it because they have more grip and get more understanding for what they do.
But then as always, you have also some organizations, but they are really the minority. There are some organizations that have such aggressive tax structures that when they come into the open, they will have a serious debate with society and shareholders and investors like pension funds on, let's call it, the moral acceptance of the structures in certain cases. But that is also a question of time, of rethinking your communication and your tax strategy to bring it more in line with your ESG strategy.
Nana Ama Sarfo: Well, that's great to know. And I also appreciate you mentioning the concepts of the materiality and double materiality, because that segues into my next question for you. I mean, as you are very well aware, there's been a lot of discussion about the concept of materiality and ESG reporting.
And that is how do companies define or identify material information that should be disclosed? And the GRI believes that materiality is double, that it is both financial and non-financial. So my question for you is in the tax world, what exactly does double materiality look like?
Eelco van der Enden: Have a look at GRI 207. It's not only the financial data on a per-country basis, but also your strategy, your risk management, and your engagement with society. And if you look at various pockets and pieces in the U.K., filing your tax strategy is already a legal obligation. So that part is already there. Your risk management and control framework. If you fall within the scope of a cooperative compliance model of horizontal monitoring type of things, you have to have your tax control framework in place otherwise it will not work and you will not get your ruling or your agreement with the tax administration. So that's the second pillar of 207.
The third one is your stakeholder engagement, or what do you disclose, what your mobile activities are, your relationships with NGOs, what your views are on tax as a part of society, which most companies have already included in a corporate communication stuff. And then it's about the tax data itself. And these are non-financial metrics, of course, because it's not on the balance sheet or in your PNL (profit and loss). It's just a story behind how you manage it, and then, of course, you have to per-country data that gives insight in what you say in your strategy indeed is true.
And it does not grow overnight because companies are living bodies that constantly change, and move, and that's why the story behind the data is also important. You can have a very low tax rate for a very good reason. You can very high tax rate for a very bad reason. It’s just explaining to society. That is the double met reality of 207. It is outside just the financial reporting whereby financial materiality is also defined as a monetizable risk of a certain magnitude that could affect your growing concern.
Nana Ama Sarfo: To close, the creation of the GRI 207 standard was a very high-profile task, but now you have an even more high-profile job as the new CEO of the GRI. So I'm hoping that you can share for our listeners some of your goals for advancing tax transparency in the short term, and also in the long term.
Eelco van der Enden: So the strategic objective in three words: alignment, alignment, alignment. We must align with the ISSB. We must align with IFRAC, and we must make sure that we will have a comprehensive set of corporate reporting standards that both address financial as well as sustainability topics, preferably in a global framework.
So everything that is possible to cooperate with ISSB and IFRAC is something we are pushing and pursuing. And that is what we call this two-pillar environment, this two-pillar strategy. So, that is the most important task I think I have to make that happen.
On a more operational point of view, as an organization, it is finding the means indeed to maintain, support, and make better more standards on some topics that society – and society is, by the way, politicians, and large businesses, and other constituencies that ask us to make and draft. So the part of finding the means and the people to support our organization to grow the standard setting, that is the second most important topic.
When it comes to tax, there is indeed a tremendous uptake of the 207 standard. And what I would like to see is that countries do not reinvent the wheel. There is a tested, proven tax transparency standard. So I hope the EU will not start to redesign or rethink its own reporting standards under public country-by-country reporting, or that the OECD will add to BEPS 13, things like that. There is a standard. Just use it. It is free to use, it is tested, it’s widely respected, and well used. So just do it.
Nana Ama Sarfo: Well, Eelco, this has been a truly enjoyable conversation, and thank you for shedding some light on this very dynamic world of ESG reporting and how it interfaces with tax. We are really grateful for your time and thank you so much for coming on the podcast.
Eelco van der Enden: Thank you very much. I'm sure we'll meet soon again.
David D. Stewart: If you’d like to learn more about van der Enden’s thoughts on ESG and tax, you can check out Ama’s article, which you'll find linked to in the show notes.
And now, coming attractions. Each week we highlight new and interesting commentary in our magazines. Joining me now is Acquisitions & Engagement Editor in Chief Paige Jones. Paige, what will you have for us?
Paige Jones: Thanks, Dave. In Tax Notes Federal, Jason Schwartz examines the most relevant U.S. tax considerations when engaging in decentralized finance transactions. Robert Wood explains how writing off legal fees just got easier for plaintiffs.
In Tax Notes State, Bruce Ely and William Thistle provide an update on the state tax treatment of LLCs and LLPs. Don Griswold examines gender inequity in state and local tax systems and provides steps state and local governments may take to reduce their tax-based structural discrimination against women.
In Tax Notes International, Noam Noked makes the case for domestic minimum taxes on multinationals. Kartikeya Singh compares two approaches for determining which countries will have to provide U.S. in-scope multinationals with relief from double taxation under amount A of the OECD's pillar 1 proposal.
In Featured Analysis, Nana Ama Sarfo discusses how flexibility and choice are integral to recent biometric identity verification efforts spearheaded by tax authorities.
On the Opinions page, Robert Goulder talks with Jenny Webster and her legal counsel, Filippo Noseda, about her lawsuit before the U.K. High Court challenging FATCA. Marie Sapirie argues that while the IRS has a number of options for modifying its notice, collection, and penalty procedures to assist taxpayers, Congress probably needs to step in if it wants the agency to halt all automatic notices.
And now, for a closer look at what’s new and noteworthy in our magazines, here is Tax Notes State Editor in Chief Jéanne Rauch-Zender.
Jéanne Rauch-Zender: Thank you, Paige. I’m here with Steven Wlodychak, former indirect state and local tax policy leader for EY. Welcome to the podcast, Steve.
Steven Wlodychak: Great to be here, Jéanne.
Jéanne Rauch-Zender: Before we jump into your exciting update, I have been asked by a few folks the origin behind the name of your column, “The Hissing Goose.” I’m aware of the meaning behind the name, but I would love for you to share with everyone the story.
Steven Wlodychak: I just love that quote, and it comes from someone named Jean-Baptiste Colbert. Not Stephen Colbert, Jean-Baptiste Colbert. Anyway, Jean-Baptiste Colbert is kind of famous in the sense that he was the finance minister to King Louis XIV for nearly 20 years, which is an achievement all by itself. Right? Could you imagine staying the finance minister for more than 20 years to King Louis XIV?
Anyway, he was responsible for raising taxes, and the famous quote comes from that where he says, “The art of taxation is picking the greatest number of feathers from the goose with the least amount of hissing.” And so my point is if you take a look at state taxation, it truly is an art. Not only do you have to satisfy local concerns so the constituents and voters as well as tax policy reasons just within your state, but you also have to worry about federal issues, and you need to stay competitive.
So that’s really where the origin of it comes from, it’s the whole idea that you have to be able to pluck the greatest number of feathers with the least amount of hissing.
Jéanne Rauch-Zender: Well, I love it. Thank you. I’m sure everyone will appreciate the update and a little bit of back story behind that. OK, so let’s move on to why we are here today.
Your upcoming article titled, “State PTE Tax Updates: Agency Guidance and Even More Differences,” will appear in the February 14 issue of Tax Notes State and provides an update to your original article. Would you provide a brief overview of this upcoming article and the recent legislation surrounding passthrough entity tax?
Steven Wlodychak: Well, the first reason for doing the article was there was a tremendous amount of administrative guidance that the states issued since we did the article originally back in August.
So, we covered the forms, the procedures, and all that stuff, and what was really fascinating to me is the wide variety of differences that the states applied with respect to administrative guidance that is critical to understanding how you’re supposed to file, how you’re supposed to register, and then the multistate issues that reflect that.
The next reason for doing it was there was a lot of new legislation enacted at the end of the year, so for example, we now have a new passthrough entity tax in Massachusetts as well as Michigan, and I wanted to provide an update of that as well.
Thirdly, there were new proposals. Ohio and Pennsylvania had proposed legislation last year that still hasn’t passed, but it’s pending in their legislatures. But in addition, in 2022, just in the beginning of the year, and Jéanne, you know this, we had to update the article several times even in the weeks since we first came up with the idea because more states jumped in on this.
We had prefiled bills in Iowa, New Mexico, Vermont, and Virginia, and get this, I just heard yesterday from one of my colleagues that West Virginia might be exploring a PTE tax as well. I haven’t seen any of the guidelines for that, but the point is we have interests there. Again, that was to provide taxpayers and our readers with an update on all these different changes that occurred.
The overriding theme still is the same thing — these state PTE tax laws are all different and the administrative forms are all different, even in states that have nearly identical PTE taxes. They all have their different rules with respect to how they will apply their PTE tax laws that I think taxpayers and tax advisors and tax preparers need to know about.
Jéanne Rauch-Zender: Thank you, Steve. You’re right. We’ve been working closely, of course, as you’ve continued to update this and have the most current version available when it’s published, which actually leads me to the question: How challenging is it to stay on top of these state developments?
Steven Wlodychak: Jéanne, you know we’ve talked about starting this article back in November. It’s taken this long to do it, and there’s two reasons. One is there is an awful lot of information out there and changes that the states made as we moved along, but the flood of information that occurred over the period of time was changing weekly.
And so that’s why we had the delay after the January 1 deadline. I know a lot of people wanted to make payments before the beginning of the year, didn’t even know how to make those payments before the beginning of the year. But again, the issue is how could you stay current, and so that’s why we’re writing the article right now.
But again, there’s a tremendous amount of administrative guidance out there from each one of the states.
Jéanne Rauch-Zender: Well, I’m very excited and again, the article will come out in the February 14 issue of Tax Notes State. It’s been a pleasure. Before I let you go, where can our listeners find you online, Steve?
Steven Wlodychak: Well, I’m still serving as a retired principal and contractor to EY, so you can reach me there at steven.wlodychak@ey.com.
Jéanne Rauch-Zender: Thank you again. It’s always wonderful to catch up. Again, very excited for this update.
You can find Steve’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: That's it for this week. You can follow me online at @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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