Inside International Tax

By KPMG LLP (U.S.)

Business Management & Marketing Business News

What's Inside International Tax about?

In the Inside International Tax podcast series, you'll hear from KPMG professionals about U.S. international tax and OECD-related tax guidance and gain concise, practical insights about the impact on multinational enterprises.

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Inside International Tax episodes:

05.02.2024
Funding the Flames: Why Foreign Multinationals Must Take Stock of the Stock Buyback Excise Tax
In this episode, we explore how the recently issued proposed regulations addressing the stock buyback excise tax can impact foreign multinationals, how they both limit and broaden the scope of the funding rule first introduced by Notice 2023-2, and what...
03.07.2024
Put Your Best FEEP Forward: Preparing for the New Section 987 Regulations
In this episode, we explore the newest set of proposed section 987 regulations, including how they have evolved in the decades since the first proposals and what taxpayers should be thinking about now as we await finalization.
02.08.2024
Notice 2023-80: FTCs, DCLs, and the GloBE Rules, Oh My!
What guidance does Notice 2023-80 provide regarding the interaction of the GloBE rules with both foreign tax credits and dual consolidated losses and what questions still remain?
12.19.2023
More on Moore: Unpacking the Recent Oral Arguments in the Moore Case
What can be gleaned from the oral arguments before the Supreme Court in Moore v. United States on the constitutionality of the mandatory repatriation tax?
11.15.2023
Cross-Border CAMT: Unpacking the International Aspects of the New IRS Notice
Exploring the international tax aspects of Notice 2023-64, which provides interim guidance on CAMT.
10.12.2023
Pillar Two Reloaded: The OECD Releases a Second Round of Administrative Guidance
What guidance was released in the second round of OECD Pillar Two administrative guidance and where do we stand on the worldwide implementation of the GloBE rules?
08.22.2023
If I(RS) Could Turn Back Time: Notice 2023-55 Offers FTC Creditability Rules Relief
What is the scope of the temporary relief being offered to taxpayers by Notice 2023-55 and what lies ahead for the final foreign tax credit regulations?
07.27.2023
Moore than Words: Supreme Court Grants Cert on Section 965 Challenge
What are the potential ramifications from the Supreme Court's decision to hear the section 965 challenge in Moore? What should taxpayers consider doing now?
06.28.2023
Ready, Set, GloBE!
How should companies prepare today for the imminent implementation of Pillar Two tomorrow?
05.25.2023
Homeward Bound: The Intangible Journey
What relief do the proposed section 367(d) regulations offer, and where do the rules fall short?
04.19.2023
Around the GloBE: Tracking the Pillar Two Rules' Progress
Update on the worldwide implementation of GloBE rules and recent OECD administrative guidance
03.29.2023
I Literally CAMT: Dealing with Your International Min Tax Issues
What are the most pressing CAMT international tax issues for which taxpayers need guidance today?
03.01.2023
Exploring the Impact of Notice 2023-7 on Transactions
Discussing Notice 2023-7 and its impact on the corporate alternative minimum tax treatment of M&A transactions
02.01.2023
What to Expect when You're Expecting Pillar Two
Discussing when U.S. multinationals can expect the GloBE rules to come online and how those rules may impact them
12.16.2022
Credit Repair: Do the Proposed Foreign Tax Credit Regulations Do Enough?
How helpful are the proposed FTC regulations in determining the creditability of corporate income taxes and royalty withholding taxes of many of our major trading partners?
10.05.2022
A Done Deal: How M&A Today Can Impact Your GloBE Liability Tomorrow
What GloBE rules should you consider in structuring M&A transactions today?
08.16.2022
CAMT Stop, Won't Stop: Corporate AMT under the Inflation Reduction Act
What do you need to know to prepare for the new corporate AMT?
08.03.2022
Ripple FX: The U.S. Tax Impact of a Strong U.S. Dollar
What are the U.S. tax implications of the recent strengthening of the U.S. dollar?
06.22.2022
A Tough Pillar to Swallow: Computing GloBE ETR for U.S. Multinationals
What kinds of risks lie ahead for U.S. multinationals as the rest of the world prepares to implement the Pillar Two GloBE rules?
05.12.2022
Planet of the APA: Liberty Global and the Future of Reg Invalidity
What are the implications of Liberty Global on challenges to the validity of Treasury regulations?
04.06.2022
No Credit Where Credit Is Due: Exploring the Practical Impact of the Foreign Tax Credit Regulations
What kinds of foreign taxes could be at risk of not receiving a credit in the U.S. under the new foreign tax credit regulations?
03.15.2022
The GloBE Rules: Bye Bye American Pie
What impact could the Global Anti-Base Erosion, GloBE, Rules have on U.S. tax incentives?
02.18.2022
Capitalization Punishment: The New Rules of Section 174
How will mandatory capitalization of R and E affect multinational corporations?
02.01.2022
The Credit Crunch: Exploring the Impact of the Final Foreign Tax Credit Regulations
How will the new foreign tax credit rules affect creditability of foreign taxes?
01.11.2022
Around the GloBE: Exploring the Pillar Two Model Rules
How does the OECD propose to implement the 15 percent global minimum tax?
11.11.2021
Back to the Build Back Better Act: Doing the Bare Minimum
What is the corporate profits minimum tax proposal, and what corporations could be targeted by this proposal?
10.21.2021
Between Two Pillars, Part 3: Mind the Gap
What more do we know now about the OECD's two-pillar approach to tackling the challenges of taxation of the digital economy?
09.30.2021
Where There's a Will, There's a Ways and Means
What are the international building blocks in the Build Back Better bill?
09.03.2021
Whither Wyden - Discussing the Discussion Draft
What has Senator Wyden's discussion draft added to the tax reform effort?
08.13.2021
ESG, OMG - The Intersection of Tax and the ESG Movement
What does Environmental, Social, and Governance, or ESG, mean for today's tax professional?
07.27.2021
Between Two Pillars, Part Deux: Consensus or Contentious?
What's the latest on the OECD's two-pillar approach to tackling the challenges of the digital economy?
06.30.2021
Red Light, Green Book: The Anti-Inversion Proposals
How would the Biden administration tax framework affect foreign takeovers of domestic businesses?
06.22.2021
Green Green Grass of Home: The Outbound Perspective of the Green Book
What does the Biden administration tax framework portend for U.S. multinational corporations?
06.16.2021
Greener on the Other Side? The Inbound Perspective of the Green BookState of Play: State Taxation of Foreign Income After the TCJA
What does the Biden administration tax framework portend for multinational corporations with U.S. operations?
05.24.2021
State of Play: State Taxation of Foreign Income After the TCJA
As multinational companies grapple with proposed new international tax rules, what do they need to keep in mind when they intersect with various jurisdictions within the United States?
04.29.2021
Between Two Pillars: The U.S. at the OECD
Will the U.S.'s recent engagement at the OECD advance BEPS 2.0, and how does BEPS 2.0 impact Tax Reform 2.0?
04.15.2021
Tax Reform Rewind: The White House and The White Paper
Gary Scanlon interviews John Gimigliano and Seth Green about Biden's Made in America Tax Plan and Wyden's Overhauling International Tax whitepaper and the contemplated, significant proposals to change the GILTI, FDII, and BEAT regimes.
04.09.2021
SPAC, Eggs, SPAC, SPAC, Bacon, and SPAC
Understanding common U.S. international tax implications of SPACs
03.22.2021
IP, Where Art Thou?
In a post-BEPS, post-TCJA environment, what should taxpayers consider when determining the location of their intellectual property?

What's Inside International Tax about?

Download our free app to listen on your phone

Inside International Tax episodes:

Funding the Flames: Why Foreign Multinationals Must Take Stock of the Stock Buyback Excise Tax

Put Your Best FEEP Forward: Preparing for the New Section 987 Regulations

Notice 2023-80: FTCs, DCLs, and the GloBE Rules, Oh My!

More on Moore: Unpacking the Recent Oral Arguments in the Moore Case

Cross-Border CAMT: Unpacking the International Aspects of the New IRS Notice

Pillar Two Reloaded: The OECD Releases a Second Round of Administrative Guidance

If I(RS) Could Turn Back Time: Notice 2023-55 Offers FTC Creditability Rules Relief

Moore than Words: Supreme Court Grants Cert on Section 965 Challenge

Ready, Set, GloBE!

Homeward Bound: The Intangible Journey

Around the GloBE: Tracking the Pillar Two Rules' Progress

I Literally CAMT: Dealing with Your International Min Tax Issues

Exploring the Impact of Notice 2023-7 on Transactions

What to Expect when You're Expecting Pillar Two

Credit Repair: Do the Proposed Foreign Tax Credit Regulations Do Enough?

A Done Deal: How M&A Today Can Impact Your GloBE Liability Tomorrow

CAMT Stop, Won't Stop: Corporate AMT under the Inflation Reduction Act

Ripple FX: The U.S. Tax Impact of a Strong U.S. Dollar

A Tough Pillar to Swallow: Computing GloBE ETR for U.S. Multinationals

Planet of the APA: Liberty Global and the Future of Reg Invalidity

No Credit Where Credit Is Due: Exploring the Practical Impact of the Foreign Tax Credit Regulations

The GloBE Rules: Bye Bye American Pie

Capitalization Punishment: The New Rules of Section 174

The Credit Crunch: Exploring the Impact of the Final Foreign Tax Credit Regulations

Around the GloBE: Exploring the Pillar Two Model Rules

Back to the Build Back Better Act: Doing the Bare Minimum

Between Two Pillars, Part 3: Mind the Gap

Where There's a Will, There's a Ways and Means

Whither Wyden - Discussing the Discussion Draft

ESG, OMG - The Intersection of Tax and the ESG Movement

Between Two Pillars, Part Deux: Consensus or Contentious?

Red Light, Green Book: The Anti-Inversion Proposals

Green Green Grass of Home: The Outbound Perspective of the Green Book

Greener on the Other Side? The Inbound Perspective of the Green BookState of Play: State Taxation of Foreign Income After the TCJA

State of Play: State Taxation of Foreign Income After the TCJA

Between Two Pillars: The U.S. at the OECD

Tax Reform Rewind: The White House and The White Paper

SPAC, Eggs, SPAC, SPAC, Bacon, and SPAC

IP, Where Art Thou?

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