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.

What should taxpayers know about the digital content and cloud regulations, and how should they prepare for their impact?

In this milestone 50th episode of the podcast, we explore the key changes in the recently issued final regulations addressing the characterization of digital content and cloud transactions, the new proposed cloud sourcing rule, and the impact these rules could have on taxpayers.

Join us as our co-hosts and are joined by , from the KPMG Value Chain Management practice, as well as and from the KPMG Washington National Tax - International Tax group, to explore these issues and more.

In this episode of Inside International Tax, we delve into the tariffs recently announced by the Trump administration, exploring the president's authority to impose them, the potential policy objectives behind their use, and the impact they could have on taxpayers and trade partners.

Join us as our host and co-host are joined by , a principal in the KPMG Washington National Tax - International Tax practice specializing in trade and customs, to explore these issues and more.

In this episode, we explore the key concepts of the recently proposed previously taxed earnings and profits, PTEP, regulations and their practical impact on taxpayers.

Join us as our host Gary Scanlon interviews his co-host Kristen Gamboa, as well as our guests Tim Chan, from the KPMG Washington National Tax - BTS Passthroughs Tax practice, and Gloria LaBerge, from the Washington National Tax - International Tax practice, to explore these issues and more.

In this episode, we explore the basics of digital transformation and value chain management, focusing on how digital intangibles and digital technologies are becoming increasingly important to taxpayers in creating value and optimizing tax outcomes.

Join us as our co-hosts Kristen Gamboa and Gary Scanlon are joined by Paul Glunt and Matt McNeill, from the KPMG Value Chain Management practice, to discuss this interesting topic on the latest episode of Inside International Tax.

In this episode, we discuss how the results of the November election in the United States may impact tax policy in the near term, including the ways in which the new Congress may be able to pass tax legislation, what roadblocks may exist, and the impact tax disruptors, such as the expiring TCJA provisions and global tax reform, may have in shaping tax policy for 2025 and beyond.

Join us as our co-hosts Kristen Gamboa and Gary Scanlon are joined by returning guests, Michael Plowgian and Dan Winnick, from the KPMG Washington National Tax, WNT, International Tax group, to answer these questions and more on the latest episode of 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.