On Feb. 13, 2022, 117 million viewers are expected to tune in to watch Super Bowl LVI. Those numbers would make it the most-watched Super Bowl ever—topping the 2015 New England Patriots and Seattle Seahawks game, which pulled in 114 million viewers.
There’s no Tom Brady in the game this year, but expectations are still high—and it’s not just a post-pandemic clamor for sports. The Cincinnati Bengals and Los Angeles Rams came out as victors in their respective conferences in what many pegged the most exciting postseason in years. The hope is that translates into an exciting championship game.
While the players are different, the Super Bowl formula is much the same this year: big stars and plenty of time for commercials. The festivities will kick off with country singer Mickey Guyton performing the National Anthem, and the halftime show will feature Eminem, Snoop Dogg, Mary J. Blige, Kendrick Lamar, and Dr. Dre. And early indicators suggest that the trend among commercials will also tilt heavily towards star power.
Super Bowl LVI also has something in common with the first Super Bowl, with both being played in Los Angeles County, Calif. The first Super Bowl was played on Jan. 15, 1967, and featured the Green Bay Packers taking on the Kansas City Chiefs. It wasn’t called the Super Bowl at first, rather the AFL-NFL World Championship. According to the NFL, Lamar Hunt, then-owner of the Kansas City Chiefs, was fascinated by the Super Ball—a toy that his kids played with—and pushed for the name “Super Bowl.”
As for the Roman numerals? Those began with Super V. They were used to avoid confusion because the Super Bowl is played in the year after the start of the season. Calling it Super Bowl 2022, for example, wouldn’t make sense to many viewers since the majority of the season occurred in 2021. In that regard, it’s not unlike our tax season—the 2021 tax year is often referred to as the 2022 tax season, although some tax professionals will refer to it as the 2021 tax season. Maybe we should consider some renaming of our own?
No matter what we call it, these weeks are some of the busiest of the year for many tax professionals. And at Bloomberg Tax, as always, our experts offer great coverage with our federal, state, and international tax analysis.
Enjoy the game!
The Exchange… It’s where great ideas intersect.
—Kelly Phillips Erb
Quick Numbers Trivia
What’s the average cost of a ticket to the past five Super Bowls?
Answer at the bottom.
Our Roundup
This week, our experts touched on a wide range of topics, from SALT workarounds to royalty tax. For a look at what’s making news, here’s our super roundup:
If you can’t score using your go-to plays, you have no choice but to find a workaround. The trend among states to adopt elective pass-through entity taxes, or PTETs, emerged as a measure to decrease the impact of the SALT cap, which was introduced under the 2017 tax law. In a two-part series, Baker Botts’ William Gorrod, Renn Neilson, Matthew Larsen, Jon Feldhammer, and Ali Foyt share how a growing number of pass-through business owners may take advantage of entity-level state tax elections as a measure of SALT cap relief. They also touch on considerations for deciding whether to make the PTET election in a given state, give an update on federal proposals to increase or eliminate the SALT cap, and summarize states’ efforts to eliminate the SALT cap at the U.S. Supreme Court.
- SALT Cap Workaround: Pass-Through Entity Tax Update, Part I
- SALT Cap Workaround: Pass-Through Entity Tax Update, Part II
Both sides need to understand the rules. In Germany Clarifies License Barrier Rule on Intra-Group Payments, Lars Haverkamp of Eversheds Sutherland Germany explains how the tax authorities have clarified the application of the German license barrier rule on intra-group royalty payments and the effect for taxpayers of the new requirements.
Sometimes, not being on the home team is an advantage. An Indian tax tribunal characterized income earned by a Singaporean company from the sale of software licenses and related support, maintenance, and training, as business income and not royalty, and therefore not chargeable to tax in the absence of a permanent establishment in India, as explained by Shailendra Sharma in Sale of Software License is Exempt from Royalty Tax in India.
What happens when the rules change in the middle of the game? In India Budget 2022 Overrides Supreme Court Ruling—History Repeats Itself, Kumar Visalaksh and Arihant Tater of Economic Laws Practice (ELP) look at several amendments in the Finance Bill 2022 which effectively nullify the judgment of the Indian Supreme Court in the Canon India case and may now cause a wave of litigation by taxpayers challenging the constitutional validity of the amendments.
Marching down the field isn’t enough—you still have to get the ball across the line. In 2021, the U.S. Treasury Department led a global tax policy process that resulted in 137 countries agreeing to new corporate income tax rules despite dim prospects of congressional action to make it law. In January, Treasury finalized new foreign tax credit regulations that could deny the credit for foreign income taxes paid under the globally-agreed rules. In U.S.-Based Multinationals Face a Double Tax Whammy, Jeff VanderWolk of Squire Patton Boggs LLP looks at the web of new rules facing U.S.-based multinational businesses.
Opinion & Commentary
Don’t rule out the competition too early. As governments around the world consider the OECD tax deal, America is facing strategic competition with China. In OECD Tax Revamp Should Not Forget China,Federal Policy Group senior tax counsel and director Aharon Friedman and Amberwave Partners co-founder Stephen Miran, say the Build Back Better Act and the OECD global tax deal would harm America’s competitiveness while helping China. America needs massive investments in its manufacturing base and workers’ skills, not a dramatic expansion of the welfare state, to reinforce our economy.
Flag on the play.
False start? The IRS is going after the gig economy, dramatically lowering the threshold for reporting income outside traditional workplaces. But, writes Alexis Leondis in The IRS Can’t Figure Out How to Tax Gig Workers, if you’ve been keeping your side hustle off the books, the new rule probably won’t be what forces you to come clean.
In either game, life or football, the margin for error is so small. The expanded child tax credit lapsed in December as the cost of President
Columnists & Contributors
Always think about the next play. This week, the IRS confirmed that it would stop requiring taxpayers to use facial-recognition software to access online services. But what comes next? The announcement left taxpayers with more questions than it did answers, and the IRS can’t just leave the mouse in the trash can.
Watching the clock matters. Next week, hopeful taxpayers will begin checking bank accounts for tax refunds. Tax season opened on Jan. 24, and the IRS says most taxpayers who file a tax return with no issues should expect a refund within 21 days if they file electronically and choose direct deposit. Here’s A Quick Update on Returns and Refunds During Tax Season.
Listen In
An all-out blitz can knock you back on your heels. When the pandemic hit, tax enforcers at state revenue departments were still grappling with the Supreme Court’s 2018 Wayfair decision. Now, legislatures are relying on these understaffed revenue departments to collect as much taxes as possible to keep post-pandemic budget gaps to a minimum. In this week’s episode of Talking Tax, Bloomberg Tax’s Michael J. Bologna talks with Greg Matson and Nancy Prosser of the Multistate Tax Commission about their priorities for this year and about why working remotely just isn’t as satisfying for tax auditors.
Game on. In this week’s episode of the Taxgirl podcast, I talk with Mark Steber, a Senior Vice President and Chief Tax Information Officer at Jackson Hewitt Tax Service, about what taxpayers should know and expect this tax season.
Get Caught Up
It’s been a busy week in tax news from state capitals to D.C. Here are some of the stories you might have missed from our Bloomberg Tax news team:
- Hoping to land a mysterious $4 billion corporate investment and 4,000 new jobs, the Kansas Legislature has hastily approved an ambitious economic development bill to attract large capital investments and phase out corporate income taxes.
- Sen.
Joe Manchin (D-W.Va.) says he wants a tax bill that would raise taxes on the wealthy, corporations, and capital gains. - U.S. consumer prices surged in January by more than expected, sending the annual inflation rate to a fresh four-decade high and adding more urgency to the Federal Reserve’s plans to start raising interest rates.
- The Justice Department’s civil division has welcomed help from small-company employees and lawyers who file qui tam complaints to root out fraud in the Paycheck Protection Program. One study says as many as 15% of the loans showed signs of fraud.
- Employees all over the world are opting to get paid in cryptocurrencies, though they’re still in a small minority, according to global payrolls and hiring company Deel.
- Companies need flexibility in adopting the new global minimum tax that the OECD tax agreement calls for, and shouldn’t just be forced to follow the organization’s model rules, an advocacy group said Thursday.
*Note: Your Bloomberg Tax login will be required to access Tax News.
Spotlight
Our Spotlight series highlights the careers and lives of tax professionals across the globe. This week’s Spotlight is on Phyllis Jo Kubey, EA CFP, NTPI Fellow—a solo practitioner based in New York City. Kubey has prepared tax returns and offered tax planning, representation, and consultation services since 1986.
Quick Numbers Answer
$6,214
Be Social
Follow Bloomberg Tax on Twitter, Facebook, Instagram, and LinkedIn—and check out Bloomberg Law on TikTok.
We also have a growing LinkedIn group where our authors, contributors, and readers can share tax-related stories and exchange ideas. We hope you’ll join the conversation!
What Did You Think?
Your feedback and suggestions are important to us, so don’t hesitate to reach out on social or email me directly at kerb@bloombergindustry.com.
To contact the reporter on this story:
To contact the editor responsible for this story:
Learn more about Bloomberg Tax or Log In to keep reading:
See Breaking News in Context
From research to software to news, find what you need to stay ahead.
Already a subscriber?
Log in to keep reading or access research tools and resources.