In this episode of Inside International Tax, we examine recent U.S. and global tax developments that have leveled the playing field for U.S. and foreign multinationals, the non-tax factors that may driving the decision whether to inbound into the U.S., and the potential costs to inbounding.

Join us as our co-hosts and interview (Principal in charge of the Complex Transactions Group and Co-Principal in charge of the WNT M&A Tax practice and , a principal in the same group, to answer these questions and more.

In this episode, we explore the evolving landscape for sovereign wealth and foreign government pension funds under section 892, highlighting the latest regulatory developments, practical implications for asset managers, and how new guidance is shaping investment strategies and compliance for global investors in the U.S. market.

Join us as our co-hosts and interview (Principal, KPMG Washington National Tax - International Tax), and (Principal, KPMG International Tax - Financial Services Group and US Tax Leader for Sovereign Wealth and Pension Funds), to answer these questions and more.

In this episode, we examine the impact on US and foreign multinationals of the OECD's Side-by-Side Package, which includes the long-awaited Side-by-Side Safe Harbor and other guidance and safe harbors intended to reduce the compliance costs of the GloBE system and protect substance-based credits.

Join us as our co-hosts and interview (Co-Principal in Charge, KPMG Washington National Tax - International Tax), along with (Tax Policy Leader and Chair of the Global Tax Policy Leadership Group - KPMG Global), and (Managing Director, KPMG Washington National Tax - Economic and Valuation Services) to answer these questions and more on the latest episode of Inside International Tax.

In this episode of Inside International Tax, we examine how recent OB3 legislative changes - including changes to domestic R&E expenses, the reinstatement of 100 percent bonus depreciation, and modifications to section 163(j) and FDII - interact with BEAT and CAMT, and what these developments mean for taxpayers.

Join us as our co-hosts and interview (Managing Director, KPMG Washington National Tax - International Tax), to review these scenarios and more on the latest episode of Inside International Tax.

In this episode, Tom Zollo, Principal in the KPMG Washington National Tax - International Tax practice, shares insights from decades in transfer pricing and international tax structuring, reflects on recent tax changes, and offers advice for navigating today's evolving landscape as he prepares for retirement.

Join us as our co-hosts and interview to cover these topics and more on the latest episode of Inside International Tax.

Doug O'Donnell joins the podcast to explore how the Mutual Agreement Procedure (MAP), a treaty-based process for resolving double taxation disputes between countries, operates at the IRS and internationally, the steps taxpayers should undertake to optimize outcomes, the complexities involved in negotiations between tax authorities, the practical challenges and trends affecting the MAP process, and alternatives to MAP for cross-border dispute resolution.

Join us as our co-hosts and interview Doug O'Donnell, formerly IRS Acting Commissioner and previously a participant in the OECD Forum on Tax Administration, to answer these questions and more on the latest episode of Inside International Tax.

In this episode of Inside International Tax, we discuss what the implications of the 'side-by-side' solution agreed to by the G7 are, and how this solution impacts U.S. parented groups and the viability of Pillar Two.

Join us as our co-hosts and interview returning guest , a Principal in the KPMG WNT - International Tax practice, and , a Principal in the KPMG WNT - Economic and Valuation Services practice, to answer these questions and more on the latest episode of Inside International Tax.

What are the key international tax provisions included in the One Big Beautiful Bill Act, and how could these provisions alter the U.S. international tax landscape?

The One Big Beautiful Bill Act made significant changes to the GILTI, FDII, BEAT and foreign tax credit regimes. In this episode, we explore how these changes may have altered the U.S. international tax landscape.

Join us as our co-hosts and interview returning guest , Principal in Charge of the KPMG Washington National Tax - International Tax group to answer these questions and more on the latest episode of Inside International Tax.

What are the key implications of the 'revenge tax' of section 899 in the 'One Big Beautiful Bill,' and which taxpayers should be concerned?

In this episode, we explore how proposed section 899 aims to counteract unfair foreign taxes through specific retaliatory measures, its applicability and scope for taxpayers, and its potential future as it progresses to the Senate.

Join us as our co-hosts and interview returning guest from the KPMG Washington National Tax - International Tax group to answer these questions and more on the latest episode of Inside International Tax.

What concessions are the United States seeking from the OECD's Inclusive Framework on the Pillar Two regime and how might they protect U.S. multinationals from over-taxation?

In this episode, we discuss the concessions the United States is seeking from the OECD's Inclusive Framework on the Pillar Two regime to protect U.S. multinationals from over-taxation and the potential international response to these demands.

Join us as our co-hosts and interview returning guest from the KPMG Washington National Tax - International Tax group to answer these questions and more on the latest episode of Inside International Tax.