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Inside International Tax Profile

Inside International Tax

English, Finance, 1 season, 39 episodes, 22 hours, 6 minutes
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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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.
3/7/202426 minutes, 16 seconds
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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?
2/8/202427 minutes, 28 seconds
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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?
12/19/202324 minutes, 41 seconds
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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.
11/15/202333 minutes, 21 seconds
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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.
11/15/202333 minutes, 22 seconds
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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?
10/12/202331 minutes, 19 seconds
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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?
39 minutes, 52 seconds
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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?
35 minutes, 3 seconds
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Ready, Set, GloBE!

How should companies prepare today for the imminent implementation of Pillar Two tomorrow?
6/28/202329 minutes, 43 seconds
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Homeward Bound: The Intangible Journey

What relief do the proposed section 367(d) regulations offer, and where do the rules fall short?
5/25/202328 minutes, 6 seconds
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Around the GloBE: Tracking the Pillar Two Rules' Progress

Update on the worldwide implementation of GloBE rules and recent OECD administrative guidance
4/19/202340 minutes, 59 seconds
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Whither Wyden - Discussing the Discussion Draft

37 minutes, 21 seconds
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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?
3/29/202336 minutes, 23 seconds
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Exploring the Impact of Notice 2023-7 on Transactions

3/1/202338 minutes, 5 seconds
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A Done Deal: How M&A Today Can Impact Your GloBE Liability Tomorrow

10/5/202234 minutes, 43 seconds
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Where There's a Will, There's a Ways and Means

50 minutes, 57 seconds
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What to Expect when You're Expecting Pillar Two

2/1/202332 minutes, 53 seconds
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Credit Repair: Do the Proposed Foreign Tax Credit Regulations Do Enough?

12/16/202239 minutes, 7 seconds
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CAMT Stop, Won't Stop: Corporate AMT under the Inflation Reduction Act

8/16/202241 minutes, 12 seconds
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Ripple FX: The U.S. Tax Impact of a Strong U.S. Dollar

8/3/202231 minutes, 5 seconds
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A Tough Pillar to Swallow: Computing GloBE ETR for U.S. Multinationals

6/22/202227 minutes, 24 seconds
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Planet of the APA: Liberty Global and the Future of Reg Invalidity

5/12/202228 minutes, 3 seconds
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No Credit Where Credit Is Due: Exploring the Practical Impact of the Foreign Tax Credit Regulations

4/6/202232 minutes, 38 seconds
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The GloBE Rules: Bye Bye American Pie

3/15/202234 minutes, 29 seconds
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Capitalization Punishment: The New Rules of Section 174

2/18/202231 minutes, 41 seconds
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The Credit Crunch: Exploring the Impact of the Final Foreign Tax Credit Regulations

2/1/202239 minutes, 57 seconds
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Around the GloBE: Exploring the Pillar Two Model Rules

1/11/202233 minutes, 26 seconds
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Back to the Build Back Better Act: Doing the Bare Minimum

11/11/202132 minutes, 57 seconds
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Between Two Pillars, Part 3: Mind the Gap

10/21/202142 minutes, 1 second
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ESG, OMG - The Intersection of Tax and the ESG Movement

8/13/202131 minutes, 22 seconds
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Between Two Pillars, Part Deux: Consensus or Contentious?

7/27/202138 minutes, 34 seconds
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Red Light, Green Book: The Anti-Inversion Proposals

6/30/202131 minutes, 53 seconds
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Green Green Grass of Home: The Outbound Perspective of the Green Book

6/22/202143 minutes, 28 seconds
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Greener on the Other Side? The Inbound Perspective of the Green BookState of Play: State Taxation of Foreign Income After the TCJA

6/16/202140 minutes, 59 seconds
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State of Play: State Taxation of Foreign Income After the TCJA

5/24/202124 minutes, 15 seconds
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Between Two Pillars: The U.S. at the OECD

4/29/202131 minutes, 14 seconds
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Tax Reform Rewind: The White House and The White Paper

4/15/202126 minutes, 13 seconds
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SPAC, Eggs, SPAC, SPAC, Bacon, and SPAC

4/9/202136 minutes, 17 seconds
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IP, Where Art Thou?

3/22/202127 minutes, 27 seconds