Inside International 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?

How should companies prepare today for the imminent implementation of Pillar Two tomorrow?

What relief do the proposed section 367(d) regulations offer, and where do the rules fall short?

Update on the worldwide implementation of GloBE rules and recent OECD administrative guidance

What are the most pressing CAMT international tax issues for which taxpayers need guidance today?