Inside International Tax

In this episode, we explore the most critical aspects of the proposed dual consolidated loss, DCL, regulations, including how a DCL used in computing a Pillar Two GloBE liability could be a 'foreign use,' the effect of intercompany transactions in computing a DCL, and the potential tax liability arising from the proposed disregarded payment loss (DPL) regime targeting deduction-no inclusion outcomes.

Join us as our co-hosts Kristen Gamboa and Gary Scanlon are joined by returning guest, Doug Holland from the KPMG Washington National Tax International Tax group, to answer these questions and more on the latest episode of Inside International Tax.

In this episode, we discuss the international tax provisions in the recently released proposed CAMT regulations, including how the proposed regulations expand the reach of the special scoping rule for foreign-parented groups, provide (mostly) taxpayer-favorable rules to address CFC double counting, and import foreign tax credit limitations and section 482 into the CAMT universe.

With the implementation of Amount B potentially around the corner, in this episode we explore Amount B, its impact on taxpayers, the cadence and contour of its global roll-out, and any lingering issues with Amount B that countries are still trying to resolve at the OECD.

In this episode, we dive into the Supreme Court's recent decision in Loper Bright Enterprises v. Raimondo to overturn Chevron v. Natural Resources Defense Council, which set out the existing framework for the interpretation of regulations issued by federal agencies, and explore its impact on the tax regulatory landscape.

In this episode, we are joined by Michael Plowgian, formerly the Deputy Assistant Secretary for International Tax Affairs at Treasury, to discuss the rapid global progress in Pillar Two enactment, the outstanding issues related to implementation, and the future of the Pillar Two initiative more broadly.

In this episode, we are joined by Michael Plowgian, formerly the Deputy Assistant Secretary for International Tax Affairs at Treasury, to explore the fundamental shift in cross-border taxation that Pillar One represents and to update us on the status of Amounts A and B, the hurdles that still exist for implementation, and the United States' current negotiating position with respect to Pillar One

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 foreign multinationals should be doing now to ready themselves for the excise tax.

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.

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?

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?