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.
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.
3/7/2024 • 26 minutes, 16 seconds
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?
2/8/2024 • 27 minutes, 28 seconds
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?
12/19/2023 • 24 minutes, 41 seconds
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.
11/15/2023 • 33 minutes, 21 seconds
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.
11/15/2023 • 33 minutes, 22 seconds
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?
10/12/2023 • 31 minutes, 19 seconds
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
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
Ready, Set, GloBE!
How should companies prepare today for the imminent implementation of Pillar Two tomorrow?
6/28/2023 • 29 minutes, 43 seconds
Homeward Bound: The Intangible Journey
What relief do the proposed section 367(d) regulations offer, and where do the rules fall short?
5/25/2023 • 28 minutes, 6 seconds
Around the GloBE: Tracking the Pillar Two Rules' Progress
Update on the worldwide implementation of GloBE rules and recent OECD administrative guidance
4/19/2023 • 40 minutes, 59 seconds
Whither Wyden - Discussing the Discussion Draft
• 37 minutes, 21 seconds
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?
3/29/2023 • 36 minutes, 23 seconds
Exploring the Impact of Notice 2023-7 on Transactions
3/1/2023 • 38 minutes, 5 seconds
A Done Deal: How M&A Today Can Impact Your GloBE Liability Tomorrow
10/5/2022 • 34 minutes, 43 seconds
Where There's a Will, There's a Ways and Means
• 50 minutes, 57 seconds
What to Expect when You're Expecting Pillar Two
2/1/2023 • 32 minutes, 53 seconds
Credit Repair: Do the Proposed Foreign Tax Credit Regulations Do Enough?
12/16/2022 • 39 minutes, 7 seconds
CAMT Stop, Won't Stop: Corporate AMT under the Inflation Reduction Act
8/16/2022 • 41 minutes, 12 seconds
Ripple FX: The U.S. Tax Impact of a Strong U.S. Dollar
8/3/2022 • 31 minutes, 5 seconds
A Tough Pillar to Swallow: Computing GloBE ETR for U.S. Multinationals
6/22/2022 • 27 minutes, 24 seconds
Planet of the APA: Liberty Global and the Future of Reg Invalidity
5/12/2022 • 28 minutes, 3 seconds
No Credit Where Credit Is Due: Exploring the Practical Impact of the Foreign Tax Credit Regulations
4/6/2022 • 32 minutes, 38 seconds
The GloBE Rules: Bye Bye American Pie
3/15/2022 • 34 minutes, 29 seconds
Capitalization Punishment: The New Rules of Section 174
2/18/2022 • 31 minutes, 41 seconds
The Credit Crunch: Exploring the Impact of the Final Foreign Tax Credit Regulations
2/1/2022 • 39 minutes, 57 seconds
Around the GloBE: Exploring the Pillar Two Model Rules
1/11/2022 • 33 minutes, 26 seconds
Back to the Build Back Better Act: Doing the Bare Minimum
11/11/2021 • 32 minutes, 57 seconds
Between Two Pillars, Part 3: Mind the Gap
10/21/2021 • 42 minutes, 1 second
ESG, OMG - The Intersection of Tax and the ESG Movement
8/13/2021 • 31 minutes, 22 seconds
Between Two Pillars, Part Deux: Consensus or Contentious?
7/27/2021 • 38 minutes, 34 seconds
Red Light, Green Book: The Anti-Inversion Proposals
6/30/2021 • 31 minutes, 53 seconds
Green Green Grass of Home: The Outbound Perspective of the Green Book
6/22/2021 • 43 minutes, 28 seconds
Greener on the Other Side? The Inbound Perspective of the Green BookState of Play: State Taxation of Foreign Income After the TCJA
6/16/2021 • 40 minutes, 59 seconds
State of Play: State Taxation of Foreign Income After the TCJA
5/24/2021 • 24 minutes, 15 seconds
Between Two Pillars: The U.S. at the OECD
4/29/2021 • 31 minutes, 14 seconds
Tax Reform Rewind: The White House and The White Paper