Inside International Tax

In this episode, we unpack the Supreme Court's recent decision holding that the International Emergency Economic Powers Act (IEEPA) does not authorize the president to impose tariffs, discuss how importers might pursue refunds, and consider what that means for Trump's trade policy going forward. Join us as our co-hosts and interview , a Principal in the KPMG Washington National Tax - Trade and Cus...

In this episode of Inside International Tax, we examine recent U.S. and global tax developments that have leveled the playing field for U.S. and foreign multinationals, the non-tax factors that may driving the decision whether to inbound into the U.S., and the potential costs to inbounding. Join us as our co-hosts and interview (Principal in charge of the Complex Transactions Group and Co-Principa...

In this episode, we explore the evolving landscape for sovereign wealth and foreign government pension funds under section 892, highlighting the latest regulatory developments, practical implications for asset managers, and how new guidance is shaping investment strategies and compliance for global investors in the U.S. market. Join us as our co-hosts and interview (Principal, KPMG Washington Nati...

In this episode, we examine the impact on US and foreign multinationals of the OECD's Side-by-Side Package, which includes the long-awaited Side-by-Side Safe Harbor and other guidance and safe harbors intended to reduce the compliance costs of the GloBE system and protect substance-based credits. Join us as our co-hosts and interview (Co-Principal in Charge, KPMG Washington National Tax - Internat...

In this episode of Inside International Tax, we examine how recent OB3 legislative changes - including changes to domestic R&E expenses, the reinstatement of 100 percent bonus depreciation, and modifications to section 163(j) and FDII - interact with BEAT and CAMT, and what these developments mean for taxpayers. Join us as our co-hosts and interview (Managing Director, KPMG Washington National Tax...

In this episode, Tom Zollo, Principal in the KPMG Washington National Tax - International Tax practice, shares insights from decades in transfer pricing and international tax structuring, reflects on recent tax changes, and offers advice for navigating today's evolving landscape as he prepares for retirement. Join us as our co-hosts and interview to cover these topics and more on the latest episod...

Doug O'Donnell joins the podcast to explore how the Mutual Agreement Procedure (MAP), a treaty-based process for resolving double taxation disputes between countries, operates at the IRS and internationally, the steps taxpayers should undertake to optimize outcomes, the complexities involved in negotiations between tax authorities, the practical challenges and trends affecting the MAP process, and...

In this episode of Inside International Tax, we discuss what the implications of the 'side-by-side' solution agreed to by the G7 are, and how this solution impacts U.S. parented groups and the viability of Pillar Two. Join us as our co-hosts and interview returning guest , a Principal in the KPMG WNT - International Tax practice, and , a Principal in the KPMG WNT - Economic and Valuation Services...

What are the key international tax provisions included in the One Big Beautiful Bill Act, and how could these provisions alter the U.S. international tax landscape? The One Big Beautiful Bill Act made significant changes to the GILTI, FDII, BEAT and foreign tax credit regimes. In this episode, we explore how these changes may have altered the U.S. international tax landscape. Join us as our co-hos...

What are the key implications of the 'revenge tax' of section 899 in the 'One Big Beautiful Bill,' and which taxpayers should be concerned? In this episode, we explore how proposed section 899 aims to counteract unfair foreign taxes through specific retaliatory measures, its applicability and scope for taxpayers, and its potential future as it progresses to the Senate. Join us as our co-hosts and...

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...

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...

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...

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 - In...

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 d...

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-...

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 outcom...

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?