Inside International Tax

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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.

KPMG LLP (U.S.)


    • Mar 7, 2024 LATEST EPISODE
    • monthly NEW EPISODES
    • 34m AVG DURATION
    • 38 EPISODES


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    Latest episodes from Inside International Tax

    Put Your Best FEEP Forward: Preparing for the New Section 987 Regulations

    Play Episode Listen Later Mar 7, 2024 26:16


    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.

    Notice 2023-80: FTCs, DCLs, and the GloBE Rules, Oh My!

    Play Episode Listen Later Feb 8, 2024 27:28


    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?

    globe ftcs
    More on Moore: Unpacking the Recent Oral Arguments in the Moore Case

    Play Episode Listen Later Dec 19, 2023 24:41


    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?

    Cross-Border CAMT: Unpacking the International Aspects of the New IRS Notice

    Play Episode Listen Later Nov 15, 2023 33:22


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

    Pillar Two Reloaded: The OECD Releases a Second Round of Administrative Guidance

    Play Episode Listen Later Oct 12, 2023 31:19


    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?

    If I(RS) Could Turn Back Time: Notice 2023-55 Offers FTC Creditability Rules Relief

    Play Episode Listen Later Aug 23, 2023 39:52


    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?

    Moore than Words: Supreme Court Grants Cert on Section 965 Challenge

    Play Episode Listen Later Aug 2, 2023 35:03


    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?

    Ready, Set, GloBE!

    Play Episode Listen Later Jun 28, 2023 29:43


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

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    Homeward Bound: The Intangible Journey

    Play Episode Listen Later May 25, 2023 28:06


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

    Around the GloBE: Tracking the Pillar Two Rules' Progress

    Play Episode Listen Later Apr 19, 2023 40:59


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

    I Literally CAMT: Dealing with Your International Min Tax Issues

    Play Episode Listen Later Mar 29, 2023 36:23


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

    CAMT RuM&Ations: Exploring the Impact of Notice 2023-7 on Transactions

    Play Episode Listen Later Mar 1, 2023 38:05


    What to Expect when You're Expecting Pillar Two

    Play Episode Listen Later Feb 1, 2023 32:53


    Credit Repair: Do the Proposed Foreign Tax Credit Regulations Do Enough?

    Play Episode Listen Later Dec 16, 2022 39:07


    A Done Deal: How M&A Today Can Impact Your GloBE Liability Tomorrow

    Play Episode Listen Later Oct 5, 2022 34:43


    CAMT Stop, Won't Stop: Corporate AMT under the Inflation Reduction Act

    Play Episode Listen Later Aug 16, 2022 41:12


    Ripple FX: The U.S. Tax Impact of a Strong U.S. Dollar

    Play Episode Listen Later Aug 3, 2022 31:05


    A Tough Pillar to Swallow: Computing GloBE ETR for U.S. Multinationals

    Play Episode Listen Later Jun 22, 2022 27:24


    Planet of the APA: Liberty Global and the Future of Reg Invalidity

    Play Episode Listen Later May 12, 2022 28:03


    No Credit Where Credit Is Due: Exploring the Practical Impact of the Foreign Tax Credit Regulations

    Play Episode Listen Later Apr 6, 2022 32:38


    The GloBE Rules: Bye Bye American Pie

    Play Episode Listen Later Mar 15, 2022 34:29


    Capitalization Punishment: The New Rules of Section 174

    Play Episode Listen Later Feb 18, 2022 31:41


    The Credit Crunch: Exploring the Impact of the Final Foreign Tax Credit Regulations

    Play Episode Listen Later Feb 1, 2022 39:57


    Around the GloBE: Exploring the Pillar Two Model Rules

    Play Episode Listen Later Jan 11, 2022 33:26


    globe pillar model rules pillar two
    Back to the Build Back Better Act: Doing the Bare Minimum

    Play Episode Listen Later Nov 11, 2021 32:57


    Between Two Pillars, Part 3: Mind the Gap

    Play Episode Listen Later Oct 21, 2021 42:01


    Where There's a Will, There's a Ways and Means

    Play Episode Listen Later Sep 30, 2021 50:57


    Whither Wyden - Discussing the Discussion Draft

    Play Episode Listen Later Sep 3, 2021 37:21


    wyden discussion draft
    ESG, OMG - The Intersection of Tax and the ESG Movement

    Play Episode Listen Later Aug 13, 2021 31:22


    Between Two Pillars, Part Deux: Consensus or Contentious?

    Play Episode Listen Later Jul 27, 2021 38:34


    Red Light, Green Book: The Anti-Inversion Proposals

    Play Episode Listen Later Jun 30, 2021 31:53


    Green Green Grass of Home: The Outbound Perspective of the Green Book

    Play Episode Listen Later Jun 22, 2021 43:28


    Greener on the Other Side? The Inbound Perspective of the Green BookState of Play: State Taxation of Foreign Income After the TCJA

    Play Episode Listen Later Jun 16, 2021 40:59


    State of Play: State Taxation of Foreign Income After the TCJA

    Play Episode Listen Later May 24, 2021 24:15


    Between Two Pillars: The U.S. at the OECD

    Play Episode Listen Later Apr 29, 2021 31:14


    Tax Reform Rewind: The White House and The White Paper

    Play Episode Listen Later Apr 15, 2021 26:13


    SPAC, Eggs, SPAC, SPAC, Bacon, and SPAC

    Play Episode Listen Later Apr 9, 2021 36:17


    IP, Where Art Thou?

    Play Episode Listen Later Mar 22, 2021 27:27


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