Inside International Tax

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?

Exploring the international tax aspects of Notice 2023-64, which provides interim guidance on CAMT.

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?

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?

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?