Podcasts about international tax

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international tax

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Best podcasts about international tax

Latest podcast episodes about international tax

The IDEAL Investor Show: The Path to Early Retirement
Best Tax-Efficient Advice to Reduce your Tax in 30 Minutes | Tax Expert Interviews

The IDEAL Investor Show: The Path to Early Retirement

Play Episode Listen Later Mar 26, 2025 32:18


Trouble with taxes as a foreigner with business in the US? Or how can you legally reduce your tax to $0? Adam Bergman is a 9-time author, former tax and ERISA attorney, and the founder of IRA Financial - an industry leader in self-directed retirement solutions. Adam is a leading voice in the self-directed retirement industry and has been interviewed on CBS News and quoted in over one hundred and thirty major news publications in retirement tax planning - listen to one of the best tax interviews this season.***DON'T KNOW WHERE TO START WITH FRANCHISING? Grab Bob Bernotas' free course for a limited time only at edu.franchisewithbob.com/ideal***WHY LISTEN TO OUR INTERVIEW WITH ADAM BERGMAN:[00:00-04:40] It all started with IRAs[04:41-07:25] Real Estate Investments with IRA and 401k[07:26-15:02] Leverage saving accounts BETTER I[15:03-16:12] Sponsor: Franchising made easy[16:03-20:48] Leverage saving accounts BETTER II[20:49-26:44] International Investments and Tax Implications[26:45-29:37] Get the best tax advice to your door[29:38-32:18] Sometimes it's all luckReach out to Adam at  https://www.irafinancial.comAny questions?*** Interested in our $10k/month passive strategy? Just sign up for our newsletter at https://bit.ly/iwg-strategy BOOK IS OUT! Grab Your Copy and learn how to get your feet wet in real estate investing Download episodes to your favorite platforms at idealinvestorshow.com Connect with us through social! We'd love to build a community of like-minded people like YOU!

GILTI Conscience
Navigating Permanent Establishments in International Tax Law

GILTI Conscience

Play Episode Listen Later Mar 25, 2025 64:55 Transcription Available


When goods, services and rights go back and forth within a company, how do you attribute profit or loss to one part of the company versus another? Former OECD head of tax treaties and transfer pricing Mary Bennett and EY's Mike McDonald join this episode of “GILTI Conscience” for a detailed discussion on the attribution of profits to permanent establishments. Skadden tax partners David Farhat and Nate Carden and associate Stefane Victor host the discussion, which explores, among other topics, critical differences between Articles 7 and 9 of the OECD Model Tax Convention and why these distinctions matter for multinational businesses.

Law, disrupted
KPMG's Arizona Law Firm – A Paradigm Shift in Law Business

Law, disrupted

Play Episode Listen Later Mar 20, 2025 26:12


John is joined by Christian Athanasoulas, KPMG's Global Head of International Tax and M&A Tax and U.S. Tax Practice Leader – Services.  They discuss the groundbreaking shift in the U.S. legal industry arising from Arizona's decision to allow non-lawyers to have ownership interests in law firms.  This move aligns the U.S. with countries like the U.K. and Australia, where non-lawyers have been permitted to own law firms for years.  KPMG has successfully operated legal practices in over 80 countries, but U.S. regulations previously prevented it from offering legal services alongside its consulting, tax, and advisory work.  Arizona's new rules allow KPMG to offer the non-legal services it typically offers clients together with related legal services performed by the new law firm.  Previously, KPMG's clients would have to retain law firms with no formal ties to KPMG for those services.  Christian led the effort to establish KPMG Law US, a wholly owned Arizona law firm under the KPMG umbrella.  KPMG Law US is an independent LLC with Arizona-licensed lawyers and a compliance officer to ensure adherence to legal ethics rules.  Although owned by KPMG, the law firm maintains autonomy.  It can assist clients with legal matters such as contract integration and regulatory compliance.  KPMG Law US leverages its parent company's technological advancements, including AI-driven contract analysis and process automation, to improve efficiency in the provision of legal services.  The new law firm will not engage in litigation.  For matters outside of Arizona, it will co-counsel with lawyers admitted in the appropriate jurisdiction.  While Arizona is currently the only state permitting non-lawyer ownership of law firms, other states are exploring the possibility of passing similar laws.  The creation of KPMG Law US could signal broader changes in the legal profession, potentially reshaping traditional law firm structures.Podcast Link: Law-disrupted.fmHost: John B. Quinn Producer: Alexis HydeMusic and Editing by: Alexander Rossi

Retirement Tax Services Podcast
Navigating International Tax Waters with Renato Baccaro

Retirement Tax Services Podcast

Play Episode Listen Later Mar 17, 2025 26:07


This week, Steven dives into international waters with special guest Renato Baccaro. Renato has spent years dedicated to creating a tool to help people navigate the rules and regulations of tax jurisdictions the world over. While it's not a simple question and one that might feel best left to the experts, where are you going to find those experts? More and more people see international travel, extended stays, and even relocation as a viable option and the tax laws just keep getting more complicated. Renato breaks his mission down very simply: you can get online and compare flight options and prices at the click of a button, he wants to create the tax equivalent for deciding where to live https://zurl.co/VwEuS

EY talks tax
EY talks tax: International tax talk quarterly series with the EY Global Tax Desk Network (February 19, 2025)

EY talks tax

Play Episode Listen Later Feb 26, 2025 59:04


In this episode, panelists discuss tax policy developments around the world. 

The Week In Tax
President Trump is blowing up the international tax order, is our Netflix tax a tariff? Time running out on a GST election

The Week In Tax

Play Episode Listen Later Feb 22, 2025 21:00


This week as President Trump blows up the international tax order, could our Netflix tax be under threat of retaliation? Time running out for a potentially important GST election and notes from this year's International Fiscal Association conference.

Future of Tax
Is your company ready for Pillar Two's Global Minimum Tax?

Future of Tax

Play Episode Listen Later Jan 15, 2025 18:08


Contributed by Christian Athanasoulas, Tax Practice Leader – Services, KPMG LLP, and Global Head of International Tax and M&A Tax, KPMG International; Janette Wilkinson, Partner, KPMG in the UK and Global BEPS Leader, KPMG International; Andy Baik, Tax Partner and BEPS Center of Excellence Leader, KPMG in Singapore; and Shawn Brade, National Service Line Leader, International Corporate Tax, KPMG in Canada, this podcast is created for those clients just beginning their journey or those that have taken steps forward but need to validate work completed to date.

Cross-border tax talks
Pillar Two: UK update

Cross-border tax talks

Play Episode Listen Later Dec 12, 2024 31:59


Doug McHoney (PwC's International Tax Services Global Leader) is joined by returning guest Matt Ryan, a PwC International Tax Partner based in London and leader of PwC UK's International Tax and Treasury Network. Doug and Matt discuss a selective list of Pillar Two issues and topics related to the UK Finance Bill 2024-25. They provide an update on the latest Pillar Two happenings, including the transposition of the June 2024 OECD Administrative Guidance into UK law, the potential for retroactive provisions, UK compliance requirements, the potential for changes in light of the US election, and what could be next. 

Talking Tax
US Companies Ready International Tax Asks in 2025 Bill

Talking Tax

Play Episode Listen Later Dec 4, 2024 13:57


US companies are ramping up their efforts to lobby Congress on the international tax provisions they'd like to see in a comprehensive 2025 tax bill.   Among their priorities is retaining the current rates on foreign income, which were included in Republicans' 2017 tax law and are poised to increase in 2026. But there are open questions about how lawmakers can pay for these extensions and make good on President-elect Donald Trump's domestic corporate tax proposals. On this week's episode of "Talking Tax," reporter Lauren Vella sits down with Rohit Kumar, co-leader of PwC's National Tax Office, to discuss which international tax provisions could be addressed in a 2025 bill. He also offers insight into how companies are thinking about the 15% global minimum tax with Republicans taking full control of the White House and Congress. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690

EY talks tax
EY talks tax: International tax talk quarterly series with the EY Global Tax Desk Network (November 12, 2024)

EY talks tax

Play Episode Listen Later Dec 3, 2024 58:07


In this episode, panelists discuss the latest global tax developments and issues to consider by year-end.

Digital Nomad Experts - Beach Commute
Navigating taxes as a digital nomad w/ international tax expert Bobby Casey | Ep 175

Digital Nomad Experts - Beach Commute

Play Episode Listen Later Nov 25, 2024 79:15


The tax episode you've been waiting for! In this can't-miss episode, Marisa interviews international tax expert and consultant, Bobby Casey, who specializes in tax residency, company structuring, and asset protection for digital nomads and entrepreneurs.  Bobby's extensive experience and practical advice have made him THE go-to expert for location-independent professionals like you to navigate the complexities of global taxation (when Marisa met Bobby at a digital nomad conference back in 2022, she signed up for his services immediately). Whether you're a remote worker dreaming of a nomadic lifestyle or an entrepreneur operating internationally, this episode is packed with essential insights to help you understand tax obligations, avoid costly mistakes, and optimize your setup. What You'll Learn in This Episode: 1. Tax Residency Explained: The key differences between citizenship, residency, and tax residency—and why it matters for nomads. 2. Myths vs. Facts: Why the "183-day rule" isn't as straightforward as you might think. 3. Tax Optimization Strategies: -How to legally minimize taxes while staying compliant. -The Foreign Earned Income Exclusion (FEIE): How Americans can qualify and save. 4. Residency Options: -Best countries for digital nomads and how to choose a residency that works for your lifestyle. -Examples of tax-friendly nations and their unique benefits. 5. Digital Nomad Visas: -When they make sense and their impact on taxes. -Key differences between tourist visas and nomad visas. 6. Common Mistakes to Avoid: -The dangers of relying on blog advice or hearsay. -Real-life cautionary tales from Bobby's clients. If you're curious about the logistics of paying (and saving!) taxes while you work remotely and travel the globe, Bobby breaks the details down for you in in clear, actionable terms.  Whether you're just starting your digital nomad journey or looking to optimize your existing setup, this episode provides valuable advice tailored to your unique situation. Resources Mentioned: Want personal , 1:1 zoom calls with Bobby to get help with your taxes? This program is for you (we use this too!)  Need help setting up your business formation and receiving mail while you're abroad? This resource from Bobby is for you (we also use this for Beach Commute!) IRS Form 2555 for FEIE Want to get emails from so you never miss tips like these? Sign up here. *The information provided in this episode is for general informational purposes only and does not constitute legal, financial, or tax advice. Every individual's tax situation is unique, and the content discussed may not apply to your specific circumstances. We strongly recommend consulting with a qualified tax professional or legal advisor before making any decisions based on the information shared in this podcast.

Cross-border tax talks
Pillar Two in Belgium: First out of the gate

Cross-border tax talks

Play Episode Listen Later Nov 14, 2024 38:11


Doug McHoney (PwC's International Tax Services Global Leader) is joined by Pieter Dere, Tax Partner in PwC Belgium, part of PwC's International Tax and Transfer Pricing Group, and PwC Belgium's Pillar Two leader. Doug and Pieter cover the latest Pillar Two developments in Belgium, including how Belgium is incorporating the latest Pillar Two administrative guidance, how tax authorities are preparing, advance tax payments, registration requirements, the Qualified Domestic Minimum Top-up Tax (QDMTT) return, the interaction of the Belgium patent box regime with Pilar Two, and the constitutionality of the Undertaxed Profits Rule (UTPR), among other topics. 

Afternoons with Rob Breakenridge
Nazem Kadri, "Dreamer: My Life on the Edge”; Denise Hearn, "The Big Fix”; B.C.'s uncertain election results; Canada slides on International Tax Competitive Index rankings

Afternoons with Rob Breakenridge

Play Episode Listen Later Oct 21, 2024 52:49


Today's guests: Nazem Kadri - NHL player for the Calgary Flames / first Muslim hockey player to win the Stanley Cup/ Author - "Dreamer: My Life on the Edge” Denise Hearn - Co-author of The Big Fix: How Companies Capture Markets and Harm Canadians" Keith Baldrey - Global BC's Legislature Bureau Chief Jake Fuss - Director of Fiscal Studies for the Fraser Institute Learn more about your ad choices. Visit megaphone.fm/adchoices

EY talks tax
EY talks tax: International tax talk quarterly series with the EY Global Tax Desk Network (October 8, 2024)

EY talks tax

Play Episode Listen Later Oct 17, 2024 57:46


In this episode, panelists discuss anti-hybrid mismatch provisions and perspectives from across the world. 

Earmark Accounting Podcast | Earn Free CPE
From SoCal to Tokyo: One CPA's Journey in International Tax

Earmark Accounting Podcast | Earn Free CPE

Play Episode Listen Later Oct 6, 2024 58:46


Join Blake Oliver for an interview with Eric Azevedo, a California CPA who has set up his own international tax practice in rural Japan. Discover how Eric leveraged his Japanese language skills to break into Tokyo's accounting scene and the unique challenges he faced. We'll delve into the complexities of international taxation, U.S. expat issues, and strategies for effective cross-border tax preparation. Whether you're planning an international move or interested in global accounting, gain valuable insights from Eric's journey and learn how to bridge cultures in the world of tax. Don't miss this opportunity to enhance your international tax expertise!(Originally recorded on September 16, 2024, on Earmark Webinars+)SponsorShareFile - https://earmarkcpe.promo/sharefileChapters(01:19) - Eric's Journey from Philosophy to Accounting (03:04) - Life and Career in Japan (04:19) - Transitioning Back to the US and Becoming a CPA (05:56) - Experiences in the California Community College System (07:49) - Living in Japan: City vs Countryside (10:44) - Starting an Accounting Career in Japan (17:32) - Cultural Adjustments and Work-Life Balance (27:00) - Working with Expats and Tax Complexities (31:41) - Understanding Tax Penalties for Expats (32:48) - Streamline Procedures for Tax Compliance (33:59) - Navigating the Japanese Tax System (37:37) - Remote Work and Connectivity in Japan (40:56) - Building a Home in Rural Japan (43:19) - Managing a Growing Client Base (53:03) - Cultural Nuances in International Accounting (55:18) - Travel Tips and Destinations in Japan (57:42) - Conclusion and Contact Information Sign up to get free CPE for listening to this podcasthttps://earmarkcpe.comDownload the Earmark CPE App Apple: https://apps.apple.com/us/app/earmark-cpe/id1562599728Android: https://play.google.com/store/apps/details?id=com.earmarkcpe.appConnect with Our Guest, Eric AzevedoLinkedIn: https://www.linkedin.com/in/ericazevedoConnect with Blake Oliver, CPALinkedIn: https://www.linkedin.com/in/blaketoliverTwitter: https://twitter.com/blaketoliver/

International Tax Bites
Episode 76: International Tax Cooperation Turf War Part II - The UN Strikes Back! with Hassans' Grahame Jackson and Old Square Tax Chambers' Harriet Brown.

International Tax Bites

Play Episode Listen Later Aug 23, 2024 66:53


In this episode Harriet and Grahame discuss the recently published Terms of Reference for a United Nations Framework Tax Convention... What is it? How far will it go? Will it succeed? What will happen if the OECD and the UN don't back down? All this and more!

The Regulatory 15/15
Updates from the Department for International Tax Co-operation (DITC) and to the Beneficial Ownership Regime (BOR)

The Regulatory 15/15

Play Episode Listen Later Aug 16, 2024 25:21


In this episode, Chris Capewell, Alex Howard, Anthony Mourginos and Jennifer Parsons discuss:Department for International Tax Co-operation (DITC) UpdateBeneficial Ownership Regime (BOR) UpdateSpeakers:Chris Capewell, Partner | +1 345 814 5666 | chris.capewell@maples.com | View bioAlex Howard, Partner | +1 345 814 5179 | alex.howard@maples.com | View bioAnthony Mourginos, Associate | +345 814 5155 | anthony.mourginos@maples.com | View bioJennifer Parsons, Professional Support Lawyer | +345 814 5155 | jennifer.parsons@maples.com | View bioResources:Click here for Presentation slidesRelated Services:Maples Group Regulatory and Financial Services AdvisoryWith a depth of experience across all regulated sectors, the Maples Group Regulatory and Financial Services team is positioned to address client needs and sensitivities. We have the largest dedicated Cayman Islands Regulatory and Financial Services team in the offshore market.Follow Us: LinkedIn: https://www.linkedin.com/company/maplesgroup/Instagram: https://www.instagram.com/maplesgroup/Twitter: https://twitter.com/maplesgroupFacebook: https://www.facebook.com/maplesgroup/Website: https://maples.com/podcasts/15-15

From Zero to Millions: Accounting Edition
How to Navigate International Tax with Mariya Luqmani

From Zero to Millions: Accounting Edition

Play Episode Listen Later Aug 7, 2024 24:51


In this exciting episode, we dive deep into the world of international tax with our distinguished guest, Mariya Luqmani. She is an international tax expert whose incredible journey from India to the US has equipped her with unique insights and expertise. Mariya provides invaluable advice on staying compliant with international tax regulations, which is crucial for any business operating on a global scale. Furthermore, we discuss the benefits of outsourcing and the power of collaboration in the accounting field. We emphasize how these strategies can lead to substantial growth and success.Tune in to gain a wealth of knowledge and practical tips from Mariya and learn how to navigate the complex landscape of international tax with confidence!What you'll hear in this episode:[1:00] Introduction to Mariya Luqmani, international tax expert[2:55] Mariya's journey from India to the US[6:10] Leveraging technology in accounting[13:05] International tax compliance[20:55] Outsourcing and collaborationConnect with Mariya https://linkedin.com/in/mariyaluqmani/Email your questions regarding international tax mariya@mlcpas.netConnect with Kelly https://www.linkedin.com/in/kellyrohrs/Connect with Bilal https://www.linkedin.com/in/bmehanna/

International Tax Bites
Ep 74: The UK-Spain-Gibraltar Tax Treaty - International Tax Bites and Tax Snax with Old Square Tax Chambers' Harriet Brown and Hassans' Grahame Jackson

International Tax Bites

Play Episode Listen Later Jul 24, 2024 84:33


This special episode is in honour of the publication of "On the principles of Gibraltar Taxation" a book edited by Grahame and available from www.spiramus.com In this episode Harriet and Grahame discuss the UK/Spain Tax Treaty on Gibraltar. This unique document which was a consequence of Brexit governs the tax interaction between Gibraltar and Spain deserve consideration on its own.

EY talks tax
EY talks tax: International tax talk quarterly series with the EY Global Tax Desk Network (May14, 2024)

EY talks tax

Play Episode Listen Later Jun 10, 2024 58:43


In this episode, panelists discuss regional and local-country tax implications of post-merger integrations carried out by US multinational entities.

Cross-border tax talks
Pillar Two: Hindsight is 20/24

Cross-border tax talks

Play Episode Listen Later May 10, 2024 46:50


Doug McHoney (PwC's Global International Tax Services Leader) and podcast regular Calum Dewar (Principal, International tax services) are at PwC's EMEA's International Tax, Legal, and Workforce Academy in Prague, Czech Republic, to discuss the latest happenings around Pillar Two. Doug and Calum examine the many practical issues taxpayers, governments and tax advisors are facing to implement the new rules, including disparity in financial accounting, the QDMTT safe harbour, arbitrage arrangements, GloBE reorganization rules, and allocation of deferred taxes.

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 3 May 2024

EY Cross-Border Taxation Alerts

Play Episode Listen Later May 6, 2024 5:23


A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee hearing highlighted expiring TCJA, OECD BEPS – IRS updates rules for requesting PLRs on Section 355 transactions.

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 26 April 2024

EY Cross-Border Taxation Alerts

Play Episode Listen Later Apr 26, 2024 5:17


A review of the week's major US international tax-related news. In this edition: US tax policy lines being drawn ahead of 2024 election, TCJA ‘cliff' – IRS finalizes domestically controlled qualified investment entity rules under FIRPTA – IRS publishes draft digital asset Form 1099-DA – US says draft Australian ruling on cross-border computer software sales contrary to US-Australia DTT, OECD Model Treaty – OECD releases consolidated GloBE commentary document, revised GloBE examples.

Future of Tax
BEPS considerations for General Counsels

Future of Tax

Play Episode Listen Later Apr 17, 2024 19:22


Nick Roome, Head of Global Solutions for KPMG Law; Grant Wardell-Johnson, Global Tax Policy Leader and Chair of the Global Tax Policy Leadership Group, KPMG International; and Christian Athanasoulas, Global Head of International Tax & M&A Tax, delve into BEPS 2.0 and its potential impacts and considerations for General Counsel. 

Legacy
People First: Building a Kind and Flexible CPA Culture

Legacy

Play Episode Listen Later Apr 15, 2024 16:48


Yoann Brugiere, a French and American CPA, embarked on a journey that led him to question the traditional methodologies of CPA firms. After years of working in various firms, he felt a common thread in the industry's approach. This realization fueled his desire to break free from the norm and establish his own CPA firm, RBIZ, with a distinct modern approach. Yoann's passion for redefining the CPA culture stemmed from his belief in kindness as the cornerstone of all relationships and a crucial value in the business world. His firm's emphasis on work-life balance and leveraging technology showcases his commitment to creating a progressive work environment. Yoann's innovative mindset and focus on embracing diversity and the importance of training have resulted in the exponential growth of Orbiss. His journey is a testament to the power of challenging the status quo and building a legacy that prioritizes people and modernity. Topics covered in this Episode: How to strategically leave a lasting impact on your business with a legacy that stands the test of time. The challenges professionals face within big CPA firms and learn how to navigate them effectively. Prioritize work-life balance and explore its crucial role in shaping a positive CPA culture for enhanced well-being. The key moments in this episode are: 00:00:00 - Introduction and Background 00:04:00 - Gaining Confidence and Making the Leap00:05:59 - Vision for Orbiss and Differences 00:09:27 - The Future of Technology in Accounting 00:11:57 - Collaboration and International Tax 00:14:05 - Vision and Goal for Orbiss 00:14:36 - Legacy and Teamwork 00:15:00 - Market Disruption 00:15:32 - Finding a Fit with Orbiss00:16:18 - Conclusion and Call to Action  Contact Yoann directly via email at Yoann@orbiss.us for tax and compliance services related to starting a subsidiary in the US or expanding a US-based firm internationally. Visit the Orbiss website at orbiss.com for more information on their services and to find contact details for Yoann and the team. If you are a company looking to expand internationally or start a subsidiary in the US, Orbiss specializes in providing tax and compliance services tailored to your needs. For more information about the Legacy Podcast and its co-hosts, visit businesslegacypodcast.com to access the shownotes and additional resources on the episode. Contact Yoann directly via email at Yoann@orbiss.us for tax and compliance services related to starting a subsidiary in the US or expanding a US-based firm internationally. Visit the Orbiss website at orbiss.com for more information on their services and to find contact details for Yoann and the team. If you are a company looking to expand internationally or start a subsidiary in the US, Orbiss specializes in providing tax and compliance services tailored to your needs. For more information about the Legacy Podcast and its co-hosts, visit businesslegacypodcast.com to access the shownotes and additional resources on the episode.    

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 12 April 2024

EY Cross-Border Taxation Alerts

Play Episode Listen Later Apr 12, 2024 3:47


A review of the week's major US international tax-related news. In this edition: IRS releases proposed stock buyback excise tax regulations – US Treasury official discusses BEPS 2.0 Pillar Two negotiations – Congressional Joint Committee on Taxation reviewing global developments in updating BEPS Pillar Two analysis – OECD official says Pillar One Multilateral Convention on Amount A moving forward.

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 29 March 2024

EY Cross-Border Taxation Alerts

Play Episode Listen Later Mar 29, 2024 3:51


A review of the week's major US international tax-related news. In this edition: US Treasury Secretary affirms commitment to BEPS Pillar One, US R&D in Pillar Two – US government officials offer international regulatory update.

International Tax Bites
Ep 68: Designing the Perfect International Tax System: The Final with Grahame Jackson Harriet Brown

International Tax Bites

Play Episode Listen Later Mar 27, 2024 80:47


In this the final episode of our mini series Designing the Perfect International Tax System Harriet and Grahame review the series and draw lessons from their guests. Have the designed a system or simply decided its really complicated? They have certainly drawn guests from all aspects of tax thought, philosophers, administrators, economists and more. Listen to find out in the conclusion of our landmark series "Designing the Perfect International Tax System"

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 22 March 2024

EY Cross-Border Taxation Alerts

Play Episode Listen Later Mar 22, 2024 3:51


A review of the week's major US international tax-related news. In this edition: Congress, Biden Administration reach agreement on budget deal; tax bill in limbo – IRS stock buyback regs weeks away, CAMT project further delayed – Mandatory binding arbitration remains US tax treaty policy – US working to protect R&D benefits under BEPS Pillar Two.

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 15 March 2024

EY Cross-Border Taxation Alerts

Play Episode Listen Later Mar 15, 2024 3:25


A review of the week's major US international tax-related news. In this edition: President Biden releases proposed FY 2025 Budget – IRS issues final revised Form W-9 with new requirement to identify direct or indirect foreign partners – US announces agreement with Türkiye to extend moratorium on unilateral measures, including DSTs.

International Tax Bites
Ep 66: with Paul Eastwood - Designing the Perfect International Tax System

International Tax Bites

Play Episode Listen Later Mar 13, 2024 59:44


In this episode Harriet and Grahame talk about the fate of small jurisdictions in the changing tax landscape, whether they can have a voice and how loud that voice can be. They are joined by Paul Eastwood of KPMG Jersey who draws on his experience in and around the OECD Inclusive Framework to give insights into how small jurisdictions with open economies can participate in the reform of the international tax system. Paul is the last guest in our miniseries "Designing the Perfect International Tax System", join us for our next episode in which we draw conclusions and decide if we have at least worked out what is required to design the perfect international tax system.

International Tax Bites
Ep 65: The International Tax Court with Harriet Brown and Grahame Jackson - Designing the perfect International Tax System

International Tax Bites

Play Episode Listen Later Mar 3, 2024 45:37


In this the ninth episode of the mini series "Designing the Perfect International Tax System" Harriet and Grahame discuss the practical options for an international tax court. What should it be? Who should be able to go to it? Should Harriet be its first chief justice? Look out for further episodes in this ongoing series. If you are new to the series feel free to go back to the introductory episode.

EY talks tax
EY talks tax: International tax talk quarterly series with the EY Global Tax Desk Network (February 13, 2024)

EY talks tax

Play Episode Listen Later Mar 1, 2024 58:43


In this episode, panelists discuss developments affecting cross-border intercompany cash repatriation and financing.

International Tax Bites
Ep 64: Peter Dietsch, The International Tax Court - Designing the perfect international tax system

International Tax Bites

Play Episode Listen Later Mar 1, 2024 49:04


In this the eighth episode of the mini series "Designing the Perfect International Tax System" Harriet and Grahame speak with Peter Dietsch of the University of Victoria in Canada about the philosophical need for an international tax court. They have a wide ranging discussion touching on the philosophy of property and the underpinnings of tax as a concept. Look out for further episodes in this ongoing series. If you are new to the series feel free to go back to the introductory episode.

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 1 March 2024

EY Cross-Border Taxation Alerts

Play Episode Listen Later Mar 1, 2024 5:41


A review of the week's major US international tax-related news. In this edition: US IRS exempts Form 1042 electronic filing in 2024 for US and nonresident withholding agents – IRS will no longer issue significant single issue PLRs – US Senate approves nomination of new IRS Chief Counsel – EY launches new tax podcast series.

International Tax Bites
Ep 63: Mbakiso Magwape, Engaging with the Process - Designing the Perfect International Tax System

International Tax Bites

Play Episode Listen Later Feb 25, 2024 70:19


In this episode Grahame and Harriet speak to Mbakiso Magwape and discuss the processes around preparing international tax proposals and how developing countries approach the design and implementation of international proposals. Mbakiso has an extensive CV in private practice, government (he worked as Principle Legal Services Officer - Legislation & Compliance with the Botswana Unified Revenue Service) and is now a post- doctoral fellow with the International Centre for Tax and Development. He brings years of expertise and insight to a process which is regularly criticised as exclusionary and weakened by a lack of inclusion of divergent voices.

International Tax Bites
Ep 62: Carlos Protto Global Tax and Developing Nations: Part 5 - Designing the perfect international tax system

International Tax Bites

Play Episode Listen Later Feb 19, 2024 59:58


This is Part 5 of our series "Designing the Perfect International Taxation System". In this episode ⁠⁠Harriet⁠⁠⁠ and ⁠⁠⁠Grahame⁠⁠⁠ discuss "Global Tax and Developing Nations" with Carlos Protto who is a member of the UN Committee of Experts on Tax Cooperation and is a leading adviser to the Argentine Government on matters of taxation. Carlos, Harriet and Grahame discuss the role of developing nations in the international tax community and the impact of recent developments on them. The discussion touches on not only the impact of international taxation reform but also the capacity of developing nations to participate fully and whether or not the OECD or the UN is the better arena for such discussions. We are very pleased to welcome such a world leader in tax policy, if you enjoy this episode and are new to our mini-series "Designing the Perfect International Tax System" you may well enjoy our Introductory episode and earlier episodes with Dan Neidle, Sam Mitha, Daniel Bunn and Thornton Matheson. You will also find more than 57 full length stand alone episodes of International Tax Bites.

International Tax Bites
Ep 61: Sam Mitha, The development of the international tax community. Part 4 - Designing the perfect international tax system

International Tax Bites

Play Episode Listen Later Feb 16, 2024 79:42


This is Part 4 of our series "Designing the Perfect International Taxation System". In this episode ⁠Harriet⁠⁠ and ⁠⁠Grahame⁠⁠ discuss "The development of the international tax community" from the perspective of #HMRC with Sam Mitha CBE. Sam, Harriet and Grahame talk about Sam's experiences in his long career with HMRC and the Inland Revenue where he specialised in international tax policy working with teams that helped develop the UK's controlled foreign company rules and other anti-avoidance provisions. Sam was witness to the shift from tax policy being made in isolation to the comprehensive international cooperation we have today. Look out for further episodes in this ongoing series. If you are new to the series feel free to go back to the introductory episode.

KPMG Tax Now
International Tax: Intangibles, royalties and the global minimum tax

KPMG Tax Now

Play Episode Listen Later Feb 11, 2024 41:09


KPMG Partners Peter Oliver, Alia Lum and Denis Larkin, along with Manager Lydia Morris, reflect on international tax developments as they affect multinational entities, including recent case law and guidance on intangibles and royalties, preparing for Pillar 2 and other developments.

Influential Entrepreneurs with Mike Saunders, MBA
Interview with James Lavorgna, Founder of Spencer Advisory Services Discussing Succession & Legacy Planning

Influential Entrepreneurs with Mike Saunders, MBA

Play Episode Listen Later Jan 29, 2024 23:57


Mr. Lavorgna started in the insurance business in 1976 and has been in the financial services industry for 45 years. He earned his Certified Financial Planning designation in 1984. He also has earned a Bachelor of Science in Finance, Juris Doctor (Litigation), Master of Laws in International Tax and Offshore Planning, and Master of Laws in Wealth Management and Private Banking. He has been in and associated with the investment industry since 1979. And is currently an Investment Advisor Representative of Forsyth Wealth Management, Inc. fee-only Registered Investment Advisor and licensed insurance agent.He is also the Managing Member of Spencer Advisory Services, LLC, and a Certified Team Based Model Consultant.He has spent his career consulting with successful business owners and high-net-worth families.Learn More: https://spencervfo.com/Spencer Advisory Services, LLC and Forsyth Wealth Management, Inc. does not offer tax, legal advice or investment advice directly. We strongly encourage you to seek advice from your own qualified tax and/or legal experts regarding the best options for your particular circumstances. Investment advisory services are offered through FWM www.forsythwms.com. Life, long-term disability, long-term care, or other non-variable insurance products are offered individually through licensed insurance producers. All non-investment advice is offered through Spencer Advisory Services, LLC. In compliance with Circular 230, any U.S. tax advice contained in the body of this email, including attachments, was not intended or written, to be used and cannot be used, by the recipient for the purposes of avoiding penalties that may be imposed under the Internal Revenue Code or applicable state or local tax laws.Influential Entrepreneurs with Mike Saundershttps://businessinnovatorsradio.com/influential-entrepreneurs-with-mike-saunders/Source: https://businessinnovatorsradio.com/interview-with-james-lavorgna-founder-of-spencer-advisory-services-discussing-succession-legacy-planning

Business Innovators Radio
Interview with James Lavorgna, Founder of Spencer Advisory Services Discussing Succession & Legacy Planning

Business Innovators Radio

Play Episode Listen Later Jan 29, 2024 23:57


Mr. Lavorgna started in the insurance business in 1976 and has been in the financial services industry for 45 years. He earned his Certified Financial Planning designation in 1984. He also has earned a Bachelor of Science in Finance, Juris Doctor (Litigation), Master of Laws in International Tax and Offshore Planning, and Master of Laws in Wealth Management and Private Banking. He has been in and associated with the investment industry since 1979. And is currently an Investment Advisor Representative of Forsyth Wealth Management, Inc. fee-only Registered Investment Advisor and licensed insurance agent.He is also the Managing Member of Spencer Advisory Services, LLC, and a Certified Team Based Model Consultant.He has spent his career consulting with successful business owners and high-net-worth families.Learn More: https://spencervfo.com/Spencer Advisory Services, LLC and Forsyth Wealth Management, Inc. does not offer tax, legal advice or investment advice directly. We strongly encourage you to seek advice from your own qualified tax and/or legal experts regarding the best options for your particular circumstances. Investment advisory services are offered through FWM www.forsythwms.com. Life, long-term disability, long-term care, or other non-variable insurance products are offered individually through licensed insurance producers. All non-investment advice is offered through Spencer Advisory Services, LLC. In compliance with Circular 230, any U.S. tax advice contained in the body of this email, including attachments, was not intended or written, to be used and cannot be used, by the recipient for the purposes of avoiding penalties that may be imposed under the Internal Revenue Code or applicable state or local tax laws.Influential Entrepreneurs with Mike Saundershttps://businessinnovatorsradio.com/influential-entrepreneurs-with-mike-saunders/Source: https://businessinnovatorsradio.com/interview-with-james-lavorgna-founder-of-spencer-advisory-services-discussing-succession-legacy-planning

Influential Entrepreneurs with Mike Saunders, MBA
Interview with James Lavorgna, Founder of Spencer Advisory Services Discussing Tax Mitigation Strategies for Business Owners

Influential Entrepreneurs with Mike Saunders, MBA

Play Episode Listen Later Jan 25, 2024 27:13


Mr. Lavorgna started in the insurance business in 1976 and has been in the financial services industry for 45 years. He earned his Certified Financial Planning designation in 1984. He also has earned a Bachelor of Science in Finance, Juris Doctor (Litigation), Master of Laws in International Tax and Offshore Planning, and Master of Laws in Wealth Management and Private Banking. He has been in and associated with the investment industry since 1979. And is currently an Investment Advisor Representative of Forsyth Wealth Management, Inc. fee-only Registered Investment Advisor and licensed insurance agent.He is also the Managing Member of Spencer Advisory Services, LLC, and a Certified Team Model Consultant.He has spent his career consulting with successful business owners and high-net-worth families.Learn More: https://spencervfo.com/Spencer Advisory Services, LLC and Forsyth Wealth Management, Inc. does not offer tax, legal advice or investment advice directly. We strongly encourage you to seek advice from your own qualified tax and/or legal experts regarding the best options for your particular circumstances. Investment advisory services are offered through FWM www.forsythwms.com. Life, long-term disability, long-term care, or other non-variable insurance products are offered individually through licensed insurance producers. All non-investment advice is offered through Spencer Advisory Services, LLC. In compliance with Circular 230, any U.S. tax advice contained in the body of this email, including attachments, was not intended or written, to be used and cannot be used, by the recipient for the purposes of avoiding penalties that may be imposed under the Internal Revenue Code or applicable state or local tax laws.Influential Entrepreneurs with Mike Saundershttps://businessinnovatorsradio.com/influential-entrepreneurs-with-mike-saunders/Source: https://businessinnovatorsradio.com/interview-with-james-lavorgna-founder-of-spencer-advisory-services-discussing-tax-mitigation-strategies-for-business-owners

Business Innovators Radio
Interview with James Lavorgna, Founder of Spencer Advisory Services Discussing Tax Mitigation Strategies for Business Owners

Business Innovators Radio

Play Episode Listen Later Jan 25, 2024 27:13


Mr. Lavorgna started in the insurance business in 1976 and has been in the financial services industry for 45 years. He earned his Certified Financial Planning designation in 1984. He also has earned a Bachelor of Science in Finance, Juris Doctor (Litigation), Master of Laws in International Tax and Offshore Planning, and Master of Laws in Wealth Management and Private Banking. He has been in and associated with the investment industry since 1979. And is currently an Investment Advisor Representative of Forsyth Wealth Management, Inc. fee-only Registered Investment Advisor and licensed insurance agent.He is also the Managing Member of Spencer Advisory Services, LLC, and a Certified Team Model Consultant.He has spent his career consulting with successful business owners and high-net-worth families.Learn More: https://spencervfo.com/Spencer Advisory Services, LLC and Forsyth Wealth Management, Inc. does not offer tax, legal advice or investment advice directly. We strongly encourage you to seek advice from your own qualified tax and/or legal experts regarding the best options for your particular circumstances. Investment advisory services are offered through FWM www.forsythwms.com. Life, long-term disability, long-term care, or other non-variable insurance products are offered individually through licensed insurance producers. All non-investment advice is offered through Spencer Advisory Services, LLC. In compliance with Circular 230, any U.S. tax advice contained in the body of this email, including attachments, was not intended or written, to be used and cannot be used, by the recipient for the purposes of avoiding penalties that may be imposed under the Internal Revenue Code or applicable state or local tax laws.Influential Entrepreneurs with Mike Saundershttps://businessinnovatorsradio.com/influential-entrepreneurs-with-mike-saunders/Source: https://businessinnovatorsradio.com/interview-with-james-lavorgna-founder-of-spencer-advisory-services-discussing-tax-mitigation-strategies-for-business-owners

Influential Entrepreneurs with Mike Saunders, MBA
Interview with James Lavorgna Founder of Spencer Advisory Services Discussing His Virtual Family Office & Team-Based Model

Influential Entrepreneurs with Mike Saunders, MBA

Play Episode Listen Later Jan 24, 2024 25:31


Mr. Lavorgna started in the insurance business in 1976 and has been in the financial services industry for 45 years. He earned his Certified Financial Planning designation in 1984. He also has earned a Bachelor of Science in Finance, Juris Doctor (Litigation), Master of Laws in International Tax and Offshore Planning, and Master of Laws in Wealth Management and Private Banking. He has been in and associated with the investment industry since 1979. And is currently an Investment Advisor Representative of Forsyth Wealth Management, Inc. fee-only Registered Investment Advisor and licensed insurance agent.He is also the Managing Member of Spencer Advisory Services, LLC, and a Certified Team Based Model Consultant.He has spent his career consulting with successful business owners and high-net-worth families.Learn More: https://spencervfo.com/Spencer Advisory Services, LLC and Forsyth Wealth Management, Inc. does not offer tax, legal advice or investment advice directly. We strongly encourage you to seek advice from your own qualified tax and/or legal experts regarding the best options for your particular circumstances. Investment advisory services are offered through FWM www.forsythwms.com. Life, long-term disability, long-term care, or other non-variable insurance products are offered individually through licensed insurance producers. All non-investment advice is offered through Spencer Advisory Services, LLC. In compliance with Circular 230, any U.S. tax advice contained in the body of this email, including attachments, was not intended or written, to be used and cannot be used, by the recipient for the purposes of avoiding penalties that may be imposed under the Internal Revenue Code or applicable state or local tax laws.Influential Entrepreneurs with Mike Saundershttps://businessinnovatorsradio.com/influential-entrepreneurs-with-mike-saunders/Source: https://businessinnovatorsradio.com/interview-with-james-lavorgna-founder-of-spencer-advisory-services-discussing-his-virtual-family-office-team-based-model

Business Innovators Radio
Interview with James Lavorgna Founder of Spencer Advisory Services Discussing His Virtual Family Office & Team-Based Model

Business Innovators Radio

Play Episode Listen Later Jan 24, 2024 25:31


Mr. Lavorgna started in the insurance business in 1976 and has been in the financial services industry for 45 years. He earned his Certified Financial Planning designation in 1984. He also has earned a Bachelor of Science in Finance, Juris Doctor (Litigation), Master of Laws in International Tax and Offshore Planning, and Master of Laws in Wealth Management and Private Banking. He has been in and associated with the investment industry since 1979. And is currently an Investment Advisor Representative of Forsyth Wealth Management, Inc. fee-only Registered Investment Advisor and licensed insurance agent.He is also the Managing Member of Spencer Advisory Services, LLC, and a Certified Team Based Model Consultant.He has spent his career consulting with successful business owners and high-net-worth families.Learn More: https://spencervfo.com/Spencer Advisory Services, LLC and Forsyth Wealth Management, Inc. does not offer tax, legal advice or investment advice directly. We strongly encourage you to seek advice from your own qualified tax and/or legal experts regarding the best options for your particular circumstances. Investment advisory services are offered through FWM www.forsythwms.com. Life, long-term disability, long-term care, or other non-variable insurance products are offered individually through licensed insurance producers. All non-investment advice is offered through Spencer Advisory Services, LLC. In compliance with Circular 230, any U.S. tax advice contained in the body of this email, including attachments, was not intended or written, to be used and cannot be used, by the recipient for the purposes of avoiding penalties that may be imposed under the Internal Revenue Code or applicable state or local tax laws.Influential Entrepreneurs with Mike Saundershttps://businessinnovatorsradio.com/influential-entrepreneurs-with-mike-saunders/Source: https://businessinnovatorsradio.com/interview-with-james-lavorgna-founder-of-spencer-advisory-services-discussing-his-virtual-family-office-team-based-model

The Nonlinear Library
EA - International tax policy as a potential cause area by Tax Geek

The Nonlinear Library

Play Episode Listen Later Jan 24, 2024 21:09


Welcome to The Nonlinear Library, where we use Text-to-Speech software to convert the best writing from the Rationalist and EA communities into audio. This is: International tax policy as a potential cause area, published by Tax Geek on January 24, 2024 on The Effective Altruism Forum. This is more of an exploratory post where I try to share some of my thoughts and experience working in international tax. Thanks in particular to David Nash for his encouragement and help in reviewing my drafts. Summary International tax rules govern how taxing rights are allocated between countries. International tax policy is likely to be an impactful cause area: Not only is there a significant amount of tax revenue at stake, there is a broader indirect impact as international tax rules can constrain domestic tax policies. International tax rules tend to be relatively sticky, persisting for decades. In recent years, as international tax has gotten increasingly political, there may also be broader foreign policy implications. Yet international tax seems to be relatively neglected. Domestic tax issues tend to be more politicised, possibly because they affect voters more directly. International tax can be highly technical and rather opaque. Tractability depends on how you identify the "problem": In my view, a problem is that the development of international tax policy is dominated by relatively wealthy countries (particularly the US), who focus too heavily on their own national interest. While I doubt this broad problem can ever be fully "solved", I believe individuals can still play a significant role in mitigating it. Problem International tax policy plays a key role in determining how much companies are taxed and where. This in turn affects the level of tax revenue different countries get. The development of international tax policy is dominated by the Organisation for Economic Co-operation and Development (OECD), which is made up of relatively wealthy countries. The US also plays a key role in international tax policy.[1] I believe that many people currently working in international tax policy focus too heavily on their national interest over the global interest. The problems here are not ones I think we can hope to fully "solve", as the problems stem from the underlying power dynamics between developed and developing countries and the natural incentives for government officials to prioritize their own country. However, international tax policy could still be a worthwhile area to consider working in, because it seems to be a relatively neglected space where individuals can have a surprisingly large impact in mitigating these problems. Background What is international tax policy? In broad terms, international tax policy governs how taxing rights are allocated between countries as well as matters of tax administration such as information sharing and dispute resolution. Countries enter into bilateral tax treaties that aim to prevent double taxation (i.e. when two or more countries try to tax the same income) without creating opportunities for tax avoidance or evasion. In recent years, there has also been a focus on multilateral tax projects, which may or may not result in a formal tax treaty. Bilateral DTAs A bilateral double tax agreement (DTA) is a tax treaty entered into by two countries. When a person/entity resident in one country earns income from another country, both countries may attempt to tax the same income. Such double taxation would inhibit cross-border investment and trade, so countries enter into bilateral DTAs to prevent this. Depending on the circumstances, DTAs will allocate taxing rights over the income to either: the residence country - where the person/entity earning the income lives or is managed; or the source country - where the income is earned. In very broad terms, in a treaty negotiation, developed countries generally want to increase the residence country's taxing rights, because they tend to have wealthy resident...

FACET
Ep 24 - Andrew Swain

FACET

Play Episode Listen Later Nov 9, 2023 29:26


Andrew Swain, FACET of 2023, Assistant Professor of Business Law at IU South Bend. His research interests include State and local tax overlap and interact with International Tax, and the interplay between tax and corporate social responsibility.

Italian Wine Podcast
Ep. 1567 Gianluca Queiroli Interviews Raffaele Boscaini | Clubhouse Ambassadors' Corner

Italian Wine Podcast

Play Episode Listen Later Sep 21, 2023 47:41


Welcome to Episode 1567 Stevie Kim moderates Clubhouse's Ambassadors' Corner – In this episode, Gianluca Queiroli interviews Raffaele Boscaini These sessions are recorded from Clubhouse and replayed here on the Italian Wine Podcast! Listen in on this series as Italian Wine Ambassadors all over the world chat with Stevie and their chosen wine producer. Which producer would you interview if you had your pick? Co-Moderator After being an international tax consultant for 20 years, Gianluca made a career switch and joined the wine industry 8 years ago. Originally from Italy, he is now based in the Boston area where he owns and runs Wine Empire, a fine wine retailer. Gianluca holds a law degree, a Master in Accounting & International Tax, and speaks fluently three languages. He also dedicated himself to many aspects of the wine world: tasting events, writing, wine education. He became an Italian Wine Ambassador & Educator (through Vinitaly International Academy) in 2019 and is a certified French Wine Scholar, American Wine Expert, Bordeaux/Burgundy/Alsace Specialist, Sherry Wine Specialist, holds the WSET Diploma & currently a MW candidate. In 2021, he launched in the U.S. the Italian Wine Maestro Certification. Connect: Facebook @mywineempire Instagram @mywineempire Twitter @mywineempire LinkedIn @mywineempire /@gianlucaqueiroli Email: info@mywineempire.com Guest Producer Raffaele Boscaini's family has been producing wine in Triveneto for seven generations. With his father, Sandro Boscaini, founder and Chairman of Masi Agricola, leaders in the production of Amarone, based in the Valpolicella Classica area, he shares a love for Veneto, its wines and the technical and masterful approach taken to wine-making. After finishing school, he obtained a diploma from the prestigious "Wine and Spirit Educational Trust" in Great Britain. Before joining the family business, he completed numerous work experiences abroad, including, amongst the most important, with the importer Berkmann's Wine Cellars and the famous British alcoholic drinks retailers, Oddbins. After gaining experience within Masi, in various different technical and administrative roles of increasing responsibility, Raffaele is today mainly involved in marketing aspects and for years now, has been General Coordinator of the Technical Group, a team of experts in various areas from oenology to agronomy and marketing, responsible for the technical progress and the high quality of the company's wines. Together with his father and his sister, Alessandra, he is brand ambassador worldwide, particularly on the markets of North and South America and Europe. In his capacity as expert oenologist, he has been called to speak at the annual conference of the”Society of Wine Educators” on numerous occasions. Connect: Website https://www.masi.it/en More about the moderator Stevie Kim: Stevie hosts Clubhouse sessions each week (visit Italian Wine Club & Wine Business on Clubhouse), these recorded sessions are then released on the podcast to immortalize them! She often also joins Professor Scienza in his shows to lend a hand keeping our Professor in check! You can also find her taking a hit for the team when she goes “On the Road”, all over the Italian countryside, visiting wineries and interviewing producers, enjoying their best food and wine – all in the name of bringing us great Pods! To find out more about Stevie Kim visit: Facebook: @steviekim222 Instagram: @steviekim222 Website: vinitalyinternational.com/wordpress/ _______________________________ Let's keep in touch! Follow us on our social media channels: Instagram www.instagram.com/italianwinepodcast/ Facebook www.facebook.com/ItalianWinePodcast Twitter www.twitter.com/itawinepodcast Tiktok www.tiktok.com/@mammajumboshrimp LinkedIn www.linkedin.com/company/italianwinepodcast If you feel like helping us, donate here www.italianwinepodcast.com/donate-to-show/ Until next time, Cin Cin!

Cross-border tax talks
Moore v. US: Constitutionality of international tax

Cross-border tax talks

Play Episode Listen Later Sep 20, 2023 28:45


Doug McHoney (PwC's International Tax Services Global Leader) and Wade Sutton (former Deputy International Tax Counsel for the US Treasury and newly appointed ITS leader of PwC's Washington National Tax Practice) are back in Washington, D.C. to discuss the recent Supreme Court grant of certiorari for the Moore v. US case. Doug and Wade go back to their law school days to break down the Moore case, starting with the facts, procedural history, and the potential implications if Section 965 is ruled unconstitutional, including direct taxation, indirect taxation, subpart F, Section 245A, GILTI, and, as always, Pillar Two.

Marc To Markets
Cross Border Wealth Creates Unique Opportunities & Challenges

Marc To Markets

Play Episode Listen Later Jul 27, 2023 23:04


As the world gets smaller more and more families are living cross border lives. With family members living in multiple countries the planning concepts and tax considerations only get more complex. To learn more about how global families have unique investment and financial planning challenges I'm joined on this episode by Chris Opie, a Managing Director at Bernstein who leads the firm's global families practice. We cover everything from the complications of US citizens marrying not US person,  estate tax challenges, managing multiple currencies, amongst other topics. With any questions or comments, or to discuss your own financial situation, I can be reached at marc.penziner@bernstein.com or 212-969-6655.The information presented and opinions expressed are solely the views of the podcast host commentator and their guest speaker(s).  AllianceBernstein L.P. or its affiliates makes no representations or warranties concerning the accuracy of any data. There is no guarantee that any projection, forecast or opinion in this material will be realized. Past performance does not guarantee future results. The views expressed here may change at any time after the date of this podcast. This podcast is for informational purposes only and does not constitute investment advice. AllianceBernstein L.P. does not provide tax, legal or accounting advice. It does not take an investor's personal investment objectives or financial situation into account; investors should discuss their individual circumstances with appropriate professionals before making any decisions. This information should not be construed as sales or marketing material or an offer or solicitation for the purchase or sale of any financial instrument, product or service sponsored by AllianceBernstein or its affiliates.