Podcasts about itts

  • 14PODCASTS
  • 120EPISODES
  • 13mAVG DURATION
  • ?INFREQUENT EPISODES
  • Apr 5, 2025LATEST

POPULARITY

20172018201920202021202220232024


Best podcasts about itts

Latest podcast episodes about itts

The Working Athlete Podcast
#233 Beyond the Finish Line: Road Racing Safety in India with BabaVelo (Rajesh Nair): Hard Truths and Hopeful Solutions for Indian Cycling

The Working Athlete Podcast

Play Episode Listen Later Apr 5, 2025 46:55


This episode is brought to you by www.thebikeaffair.comIf you are in search of a one-stop destination that caters to all your cycling needs, our today's sponsor, The Bike Affair, is the perfect place to check out! With over 14 years of experience, The Bike Affair has established itself as a trusted source offering honest advice and exceptional service. They are offering a special treat for the listeners of this podcast. You can enjoy a 10% discount on your first order by using the code 'BIKEYVENKY' on their website.  Visit their bike store in Hyderabad or shop online by using the link www.thebikeaffair.com   In this episode I talk to my team mate at Spectrum Racing and a long time mentor for a lot of us, Rajesh Nair. Rajesh a.k.a BabaVelo has raced all around the world as an amateur over the last 25 years or so. He is very passionate about cycling and is in a privileged position of being able to travel and participate in some of the best cycling events around the world. That meant he took part in 100s of races all around the world over the years. That experience gives him a perspective that not many of us have. He is outspoken. He wears his heart on his sleeve and shares his opinion without any filters. I think, that makes it all the more valuable. To set the context for this episode, a couple of days before we sat down for this chat, he withdrew from a race we travelled to take part in because of safety concerns. He did not want to risk racing in the dark on roads with traffic. We shared constructive feedback to the organizers who were very receptive for the same. But, I thought that this is a topic all of us need to think more about. In that context, we sat down to discuss about road racing in India and safety aspects we need to take care of when it comes to racing here since we don't have closed roads. Please note that the intent is not to knock on any one race or any one organizer but to discuss openly what can be done to make racing in general safer for everyone. I hope it comes across as such and that it helps all of us think more seriously about this topic.            0:00:00  Intro0:10:15  Safety of an event0:12:35  Road closures, BBCh0:17:15  Tour of Thekkady0:19:30  CFI and closed roads0:21:40  What can be done to make events safer within the constraints of India0:25:00  Shayadhri Classic and Tour of Nilgiris formats0:22:00  Circuit Races, Gravel events 0:30:40  Mountain biking as a safer option for kids0:31:40  ITTs don't have to be 40k 0:32:50  Gravel is not bad roads0:33:50  Organizers and safety standards0:35:00  Tour of Thekkady, Safety concerns, racing in the dark, neutral zones0:43:15  Talking of categories 0:46:00  Closing       About the PodcastThe working athlete podcast is a podcast with and for working athletes from all walks of life and various sports. The goal is to provide inspiration, training tips, mental hacks, time management and life-style advice through conversations with some of the best in sport, from athletes to coaches. If you think you can benefit from this, please consider subscribing so that you don't miss the weekly episodes in future. Who is a working athlete? Someone working fulltime/part-time, entrepreneur or anyone who has to work to make ends meet and doesn't let being busy to stop him/her from pursuing an active lifestyle is a working athlete. I consider stay at home moms/dads who pursue a sport, as working athletes because homemaking is a full-time job.If you like this, share with friends who could be interested.For the visually inclined, a video version of the podcast can be found here: YouTubeOther Places you'll find the podcast on:Anchor | RSS | Apple Podcasts | Spotify | Google podcasts | Pocket Casts | Radio Public | Breaker 

Digital Insights
Invitations to Tender: A Flawed System in Need of Change

Digital Insights

Play Episode Listen Later Oct 17, 2024 7:01


Let's have an honest conversation about invitations to tender (ITTs). We've discussed this topic in the Agency Academy, and I believe it's time to address this significant issue in our industry.If you've been in the digital industry for any length of time, you've likely encountered them. They're a staple of the procurement process, especially in larger organizations and government bodies. But here's the thing: they're not working. Not for agencies, not for clients, and certainly not for the projects themselves or their end users.As someone who's been on both sides of the fence - writing proposals and evaluating them - I've seen firsthand how this process can fall short. So, let's break down why ITTs are problematic and explore some alternatives that could lead to better outcomes for everyone involved.The Agency Perspective: A Costly GambleFor agencies, responding to an ITT is often a significant investment of time and resources. It's not uncommon for teams to spend weeks crafting the perfect response, only to find out they were just there to make up the numbers. This isn't just frustrating; it's economically unsustainable.The amount of work involved in pitching is substantial. Agencies often have to dedicate significant resources to preparing detailed proposals, which takes time away from billable work and ongoing projects. This investment is made with no guarantee of success, and often with the knowledge that they may have little to no chance of winning the bid.Moreover, the limited information provided in most ITTs makes accurate pricing nearly impossible. Agencies are forced to make educated guesses about the scope and complexity of the work, often leading to either overpricing (and losing the bid) or underpricing (and losing money on the project). This lack of information and the absence of an opportunity to conduct necessary research puts agencies in a precarious position.To mitigate these risks, agencies often have to add a buffer to their pricing, which can make them less competitive. Alternatively, they might lowball their estimates to win the bid, potentially setting themselves up for financial strain or a compromised project quality down the line.The Client's Dilemma: Paying More for LessClients might think they're getting a good deal through competitive tendering, but the reality is often quite different. The costs associated with preparing unsuccessful bids don't just disappear - they're factored into the rates of successful projects. This means clients are indirectly paying for all those failed proposals, essentially subsidizing the entire tendering process across the industry.Furthermore, the ITT process often rewards the best sales pitch rather than the most suitable agency. Clients end up with partners who excel at writing proposals but may not be the best fit for their specific needs. In many cases, agencies tell the client what they want to hear rather than what they need to know, leading to misaligned expectations and potential project failures down the line.The Project Suffers: Inflexibility and Missed OpportunitiesPerhaps the most significant drawback of the ITT process is its impact on the projects themselves. The rigid specifications laid out in most tenders leave little room for agencies to bring their expertise to bear on the project's scope and approach.This inflexibility continues throughout the project, as the fixed scope makes it challenging to adapt to new insights or changing requirements. It can also lead to tension between the client and agency over what's considered "in scope," potentially damaging the relationship and the project's success.Moreover, the selection process is often weighed too heavily towards the cheapest price, NOT the best value. This can result in subpar outcomes, as the focus shifts from delivering quality and innovation to merely meeting the minimum requirements at the lowest cost.The fixed scope also means there's limited opportunity to respond to insights gained during the project, including crucial user testing results. In the fast-paced world of digital, this inflexibility can lead to outdated solutions or missed opportunities for improvement. Without the ability to pivot based on user feedback, projects risk delivering products that don't meet actual user needs, regardless of how well they adhere to the original specifications.A Better Way ForwardSo, what's the solution? While I understand the need for accountability and fairness in procurement processes, especially in public sector organizations, we need to find a middle ground that works better for all parties involved.Here are a few ideas to consider:Focus on track record and capabilities: Instead of detailed project specifications, evaluate agencies based on their past performance, case studies, and overall capabilities. This approach allows clients to select partners based on their proven expertise rather than their ability to write a compelling proposal.Paid discovery phase: Consider paying a preferred supplier to conduct a brief discovery phase. This allows for a more accurate project scope and budget, benefiting both the client and the agency. For instance, give the preferred supplier a budget you want to work within and pay them a tenth of that to run a review and recommendation phase to define the project and work out what can be delivered within that price.Phased approach: Break larger projects into smaller, more manageable phases. This reduces risk for both parties and allows for more flexibility as the project progresses. Each sub-project can be individually costed and can inform the next, allowing for adaptability and continuous improvement.Value-based selection: Shift the focus from the lowest price to the best value. This might involve considering factors like the agency's expertise, proposed approach, and potential ROI. By doing so, clients can ensure they're getting the best solution for their needs, not just the cheapest option.Implementing these changes won't be easy, especially in organizations with entrenched procurement processes. The approach of using ITTs makes sense when you're buying a fixed product or service, but it doesn't work well with digital services, which are inherently more fluid and require ongoing collaboration and adaptation.Ideally, the relationship needs to be more like hiring a contractor based on time and materials. But I accept that this is a big change to ask for, especially in larger organizations and the public sector. The alternatives suggested above can serve as a middle ground, allowing for more flexibility and better outcomes while still maintaining a structured procurement process.By adopting these approaches, we can create a system that benefits all parties involved:Agencies can invest their resources more efficiently, focusing on projects where they can truly add value.Clients can make more informed decisions, getting better value for their investment and forming partnerships with agencies that are truly suited to their needs.Projects can be more flexible and responsive to changing requirements and new insights, leading to better outcomes and more innovative solutions.The potential benefits - more successful projects, better client-agency relationships, and more efficient use of resources - make it worth pursuing these changes. It's time for our industry to move beyond the outdated ITT process and embrace a more collaborative, flexible, and value-driven approach to project procurement.If you're considering hiring an agency and find this approach intriguing, don't hesitate to reach out. I'd be delighted to discuss in more detail how you can implement these ideas.Until next time,Paul

Ernst & Young ITS Washington Dispatch
EY ITTS Washington Dispatch, July 2024

Ernst & Young ITS Washington Dispatch

Play Episode Listen Later Aug 12, 2024 19:43


A monthly review of US international tax-related developments. In this edition: US Congress begins August recess – US Supreme Court overrules Chevron deference to agency regulations – US appellate court rules NR's gain from sale of its US partnership interest attributable to inventory is not US source income – IRS final Section 367(b) regs address certain cross-border triangular reorgs, inbound nonrecognition transactions – IRS officials offer update on CAMT, PTEP guidance – IRS and Medtronic file Eighth Circuit appellate briefs arguing for different transfer pricing methods – IRS official says corporations failing to respond to TP compliance letters referred for possible examination – G20 Finance Ministers, Central Bank Governors reiterate support for BEPS 2.0 – Inclusive Framework on BEPS finalizing MLC to implement Pillar One Amount A, Amount B consensus near – OECD releases sixth edition of Corporate Tax Statistics publication, Draft User Guide for GloBE Info Return XML Schema.

How the Race was Won
ITTs and Q&As

How the Race was Won

Play Episode Listen Later Jul 29, 2024 52:42


Dane Cash and Cosmo Catalano break down the action from the time trial events at the Paris Olympics, answer some listener questions, and look ahead to the upcoming Olympic road race.

Ernst & Young ITS Washington Dispatch
EY ITTS Washington Dispatch, June 2024

Ernst & Young ITS Washington Dispatch

Play Episode Listen Later Jul 9, 2024 21:55


A monthly review of US international tax-related developments. In this edition: US House Republicans eye budget reconciliation legislation in 2025 – US Supreme Court upholds Section 965 mandatory repatriation tax – IRS finalizes regs on reporting / payment of stock repurchase excise tax – IRS releases final digital asset broker reporting regulations, transition relief for certain brokers – IRS addresses certain related-party partnership basis-transactions – IRS extends penalty relief for failure to pay estimated CAMT to installment due August 2024 – US officials comment on pending CAMT guidance – IRS clarifies changes to 2023 QI agreement in new FAQs – US suspends key provisions of US-Russia tax treaty and protocol – OECD/G20 IF releases documents on Pillar One Amount B and Pillar Two – OECD updates FAQs for MNEs participating in ICAP risk assessments.

Ernst & Young ITS Washington Dispatch
EY ITTS Washington Dispatch, May 2024

Ernst & Young ITS Washington Dispatch

Play Episode Listen Later Jun 7, 2024 20:05


A monthly review of US international tax-related developments. In this edition: US House Republicans prepare for TCJA ‘cliffs' – White House official previews President Biden's tax policy for second term – US House Ways and Means Chairman, Treasury Secretary spar over TCJA, BEPS 2.0 – US will not sign BEPS Pillar One MLC without India, China TP resolution – IRS extends transitional relief under Section 871(m) for treatment of dividend equivalents – IRS to defer applicability date re: Sections 59A and 6038A regs for qualified derivative payments – New procedures for Section 355 transaction PLRs released – CAMT regs in advanced stage – Final crypto reporting rules coming in 2024 – IRS proposed regulations on foreign trusts and large foreign gifts released – More OECD BEPS 2.0 GloBE guidance coming – BEPS Pillar One MLC on track for signature in June.

Ernst & Young ITS Washington Dispatch
EY ITTS Washington Dispatch, April 2024

Ernst & Young ITS Washington Dispatch

Play Episode Listen Later May 10, 2024 12:39


A monthly review of US international tax-related developments. In this edition: US tax policy battle lines being drawn; House Republican tax writers form 10 TCJA ‘tax teams' – US progress on global minimum tax will positively affect ongoing R&D talks, JCT updating BEPS Pillar Two analysis – IRS releases proposed rules on stock repurchase excise tax – IRS waives penalty for CAMT estimated tax – IRS final regulations on FIRPTA controlled QIE rules released – IRS releases draft Form 1099-DA on digital asset proceeds – US says draft Australian ruling on cross-border computer software sales contrary to US-Australia DTT, OECD Model Treaty – IRS releases APA report for 2023 – OECD BEPS 2.0 status update – OECD releases consolidated GloBE commentary document, revised GloBE examples.

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.

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.

Ernst & Young ITS Washington Dispatch
EY ITTS Washington Dispatch, March 2024

Ernst & Young ITS Washington Dispatch

Play Episode Listen Later Apr 5, 2024 19:04


A monthly review of US international tax-related developments. In this edition: President Biden delivers State of the Union; releases FY2025 Budget with international tax proposals – Congress passes final FY2024 funding bills, tax bill in limbo – Treasury Secretary defends Administration's BEPS position at Senate hearing – House Ways & Means Subpanel holds OECD BEPS Pillar One hearing – IRS delays Form 1042 electronic filing requirement for US and foreign W/H agents – US officials offer international regulatory update – IRS will no longer issue single-issue PLRs, instead focus on ‘transactional rulings' – IRS official discusses benefits of MAP mandatory arbitration – OECD releases update on BEPS 2.0 project – OECD Council approves update to Model commentary on exchange of information.

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.

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.

Ernst & Young ITS Washington Dispatch
EY ITTS Washington Dispatch, February 2024

Ernst & Young ITS Washington Dispatch

Play Episode Listen Later Mar 8, 2024 10:51


A monthly review of US international tax-related developments. In this edition: OECD releases final guidance on BEPS Pillar One Amount B on baseline distribution – Finalization of proposed FX regulations expected by year end, two sets of proposed Section 367 regs in first half of 2024 – US Senate approves IRS Chief Counsel nomination – IRS sending more letters regarding transfer pricing compliance – OECD releases 2024 update on peer reviews under BEPS Action 5 on harmful tax practices.

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.

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 9 February 2024

EY Cross-Border Taxation Alerts

Play Episode Listen Later Feb 9, 2024 1:52


A review of the week's major US international tax-related news. In this edition: US House-passed tax package may require Senate Finance Committee markup – Senate begins two-week recess.

Ernst & Young ITS Washington Dispatch
EY ITTS Washington Dispatch, January 2024

Ernst & Young ITS Washington Dispatch

Play Episode Listen Later Feb 9, 2024 14:35


A monthly review of US international tax-related developments. In this edition: US House passes tax package, Senate action uncertain – Congress approves CR to fund government until early March 2024 – IRS signals new Section 367(d) guidance in 2024 on repatriation of IP – US officials provide regulatory update – IRS announces cryptocurrency transactions do not need to be reported until regulations issued – User fee for APAs increase, effective 2 February 2024 – US official offers BEPS Pillar One insights – OECD releases updated estimates of the economic impact of BEPS Pillar Two.    

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

EY Cross-Border Taxation Alerts

Play Episode Listen Later Jan 26, 2024 5:18


A review of the week's major US international tax-related news. In this edition: US tax package may get House floor vote week of 29 January, future in the Senate uncertain – US officials offer international tax regulatory update on CAMT, stock buyback excise tax, cloud computing and PTEP rules – OECD releases working paper on global minimum tax and taxation of MNE profit.  

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 19 January 2024

EY Cross-Border Taxation Alerts

Play Episode Listen Later Jan 19, 2024 4:36


A review of the week's major US international tax-related news. In this edition: House and Senate tax writers release $78 billion tax package – Congress passes CR to fund the government – IRS announces cryptocurrency transactions do  not have to be reported until regulations issued.

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

EY Cross-Border Taxation Alerts

Play Episode Listen Later Jan 12, 2024 6:36


A review of the week's major US international tax-related news. In this edition: US Congress returns from recess, government spending and possible tax package on the agenda – IRS to release CAMT package shortly – Treasury official offers US position on BEPS Pillar One – OECD Working Paper addresses global minimum tax and MNE taxation – EY releases 2024 International Tax and Transfer Pricing Survey, respondents say BEPS 2.0 project expands risk of double taxation.

Ernst & Young ITS Washington Dispatch
EY ITTS Washington Dispatch, December 2023

Ernst & Young ITS Washington Dispatch

Play Episode Listen Later Jan 11, 2024 17:05


A monthly review of US international tax-related developments. In this edition: IRS interim CAMT guidance provides relief from possible double-counting of CFC earnings in AFSI – IRS hasj CAMT compliance initiative – Treasury provides guidance on creditability of BEPS Pillar Two taxes, relief for pre-GloBE DCLs and extends temporary FTC reg relief – IRS Interim guidance released on treatment of basis adjustments under Section 961(c) on inbound liquidations or asset reorganizations – US officials offer international regulatory update – US Treasury announces entry into force of US-Chile tax treaty – IRS updates list of US treaties – US Supreme Court hears oral arguments in Moore transition tax case – FASB modifies income tax disclosure rules – US HQ'ed FG500 companies increase, reversing downward trend – OECD/G20 IF releases BEPS Pillar Two GloBE rules guidance, new Pillar One MLC timeline.

The Nonlinear Library
LW - On the Contrary, Steelmanning Is Normal; ITT-Passing Is Niche by Zack M Davis

The Nonlinear Library

Play Episode Listen Later Jan 10, 2024 7:03


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: On the Contrary, Steelmanning Is Normal; ITT-Passing Is Niche, published by Zack M Davis on January 10, 2024 on LessWrong. Rob Bensinger argues that "ITT-passing and civility are good; 'charity' is bad; steelmanning is niche". The ITT - Ideological Turing Test - is an exercise in which one attempts to present one's interlocutor's views as persuasively as the interlocutor themselves can, coined by Bryan Caplan in analogy to the Turing Test for distinguishing between humans and intelligent machines. (An AI that can pass as human must presumably possess human-like understanding; an opponent of an idea that can pass as an advocate for it presumably must possess an advocate's understanding.) "Steelmanning" refers to the practice of addressing a stronger version of an interlocutor's argument, coined in disanalogy to "strawmanning", the crime of addressing a weaker version of an interlocutor's argument in the hopes of fooling an audience (or oneself) that the original argument has been rebutted. Bensinger describes steelmanning as "a useful niche skill", but thinks it isn't "a standard thing you bring out in most arguments." Instead, he writes, discussions should be structured around object-level learning, trying to pass each other's Ideological Turing Test, or trying resolve cruxes. I think Bensinger has it backwards: the Ideological Turing Test is a useful niche skill, but it doesn't belong on a list of things to organize a discussion around, whereas something like steelmanning naturally falls out of object-level learning. Let me explain. The ITT is a test of your ability to model someone else's models of some real-world phenomena of interest. But usually, I'm much more interested in modeling the real-world phenomena of interest directly, rather than modeling someone else's models of it. I couldn't pass an ITT for advocates of Islam or extrasensory perception. On the one hand, this does represent a distinct deficit in my ability to model what the advocates of these ideas are thinking, a tragic gap in my comprehension of reality, which I would hope to remedy in the Glorious Transhumanist Future if that were a real thing. On the other hand, facing the constraints of our world, my inability to pass an ITT for Islam or ESP seems ... basically fine? I already have strong reasons to doubt the existence of ontologically fundamental mental entities. I accept my ignorance of the reasons someone might postulate otherwise, not out of contempt, but because I just don't have the time. Or think of it this way: as a selfish seeker of truth speaking to another selfish seeker of truth, when would I want to try to pass my interlocutor's ITT, or want my interlocutor to try to pass my ITT? In the "outbound" direction, I'm not particularly selfishly interested in passing my interlocutor's ITT because, again, I usually don't care much about other people's beliefs, as contrasted to the reality that those beliefs are reputedly supposed to track. I listen to my interlocutor hoping to learn from them, but if some part of what they say seems hopelessly wrong, it doesn't seem profitable to pretend that it isn't until I can reproduce the hopeless wrongness in my own words. Crucially, the same is true in the "inbound" direction. I don't expect people to be able to pass my ITT before criticizing my ideas. That would make it harder for people to inform me about flaws in my ideas! But if I'm not particularly interested in passing my interlocutor's ITT or in my interlocutor passing mine, and my interlocutor presumably (by symmetry) feels the same way, why would we bother? All this having been said, I absolutely agree that, all else being equal, the ability to pass ITTs is desirable. It's useful as a check that you and your interlocutor are successfully communicating, rather than talking past each other. I...

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 5 January 2024

EY Cross-Border Taxation Alerts

Play Episode Listen Later Jan 5, 2024 4:38


A review of the week's major US international tax-related news. In this edition: US-Hungary tax treaty ceased to have effect – IRS issues interim guidance on basis adjustments re: inbound liquidations or asset reorganizations – IRS updates list of treaty partner countries – IRS broadens scope of possible private letter rulings.

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 22 December 2023

EY Cross-Border Taxation Alerts

Play Episode Listen Later Dec 22, 2023 6:40


A review of the week's major US international tax-related news. In this edition: OECD/G20 Inclusive Framework releases BEPS 2.0 Pillar Two Administrative Guidance on GloBE rules – OECD announces new BEPS Pillar One MLC timeline – US-Chile income tax treaty enters into force – US Congress adjourns until January 2024 – Congressional JCT releases Bluebook on tax legislation in 117th Congress.

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 15 December 2023

EY Cross-Border Taxation Alerts

Play Episode Listen Later Dec 15, 2023 8:07


A review of the week's major US international tax-related news. In this edition: US Treasury and IRS issue FTC guidance addressing BEPS 2.0 Pillar Two GloBE top-up taxes – IRS CAMT regs delayed to 2024, but CAMT Notice released – IRS announces active compliance campaign on CAMT – Stock buyback excise tax guidance still on track for 2023 release – IRS official says PTEP targeted notice coming soon – US government plans to finalize foreign government investment exemption regs in 2024 – IRS working on crypto-asset reporting framework regulations.

Ernst & Young ITS Washington Dispatch
EY ITTS Washington Dispatch, November 2023

Ernst & Young ITS Washington Dispatch

Play Episode Listen Later Dec 11, 2023 13:19


A monthly review of US international tax-related developments. In this edition: US Congress approves new CR, complicates options for year-end tax bill – House Ways and Means Committee clears US-Taiwan tax bill – Tax Court rules non-US partnership was securities dealer engaged in US trade or business, liable for partnership WHT – US court denies DRD after applying economic substance doctrine – IRS issues proposed regs on QBUs, including simplified elections for determining Section 987 gain or loss but restrictions on loss recognition – OECD, country officials discuss BEPS 2.0 Pillars One and Two.    

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 8 December 2023

EY Cross-Border Taxation Alerts

Play Episode Listen Later Dec 8, 2023 1:41


A review of the week's major US international tax-related news. In this edition: US Supreme Court holds oral arguments in Moore transition tax case – Congress set to adjourn next week.

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 1 December 2023

EY Cross-Border Taxation Alerts

Play Episode Listen Later Dec 1, 2023 3:13


A review of the week's major US international tax-related news. In this edition: US-Taiwan tax bill moves forward – OECD to release additional BEPS 2.0 Pillar Two guidance by year-end.

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 22 November 2023

EY Cross-Border Taxation Alerts

Play Episode Listen Later Nov 22, 2023 2:41


A review of the week's major US international tax-related news. In this edition: Prospects for US tax legislation uncertain – Canada confirms plans for Digital Services Tax, may lead to US response.

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 17 November 2023

EY Cross-Border Taxation Alerts

Play Episode Listen Later Nov 17, 2023 3:22


A review of the week's major US international tax-related news. In this edition: US Congress passes CR to fund government past 17 November deadline – Government officials offer update on CAMT, stock buyback excise tax and PTEP regs – Chilean Congress approves US-Chile tax treaty with US reservations – US proposing new deadline for signing BEPS 2.0 MLC on Amount A of Pillar One – 48 countries pledged to implement OECD Crypto-Asset Reporting Framework by 2027.

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 10 November 2023

EY Cross-Border Taxation Alerts

Play Episode Listen Later Nov 10, 2023 6:24


A review of the week's major US international tax-related news. In this edition: US Treasury and IRS release proposed regulations on Section 987, income and currency gain or loss with respect to QBUs – US court denies Section 245A DRD deduction based on economic substance – Hungary authorizes signing of new US-Hungary CCA for exchange of CbC reports – OECD, senior government officials discuss BEPS 2.0 Pillars One and Two.

Ernst & Young ITS Washington Dispatch
EY ITTS Washington Dispatch, October 2023

Ernst & Young ITS Washington Dispatch

Play Episode Listen Later Nov 9, 2023 17:15


A monthly review of US international tax-related developments. In this edition: OECD releases text of Amount A Pillar One MLC, US Treasury announces consultation – OECD/G20 IF MLC to implement Pillar Two STTR – US House elects new Speaker – US-Taiwan legislation moves forward – IRS proposed regs would amend Section 367(b) rules re cross-border triangular reorgs, inbound nonrecognition – US officials offer update on pending international guidance –  IRS informing taxpayers of Schedule UTP non-compliance – IRS sending compliance alerts to US subs of foreign-owned corporations – IRS to broaden scope of corporate PLRs – US-Chile tax treaty's US reservations reflect current policy – IRS appeals Tax Court's latest decision in Medtronic – US, Israel sign CAA on CbC report exchange – Cyprus clarifies future CbC agreement with US.

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 3 November 2023

EY Cross-Border Taxation Alerts

Play Episode Listen Later Nov 3, 2023 4:45


A review of the week's major US international tax-related news. In this edition: IRS officials provide update on FTC guidance – US Treasury official comments on BEPS 2.0 project – US engaging with Canada on proposed DST – Senate Finance Committee approves new IRS Chief Counsel.

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 27 October 2023

EY Cross-Border Taxation Alerts

Play Episode Listen Later Oct 27, 2023 5:50


A review of the week's major US international tax-related news. In this edition: US House of Representatives chooses new speaker – US-Chile tax treaty's reservations incorporated in US Model Treaty – US, Uruguay sign TIEA – IRS sending compliance alerts to 150 US-based subsidiaries of foreign-owned corporations – IRS says PTEP proposed regs now expected in early 2024 – Cyprus announces Cyprus-US CAA for exchange of CbC reports will be effective for RFYs starting on/after 1 January 2023 – OECD BEPS IF considering Pillar 2 guidance on treatment of deferred tax assets in countries with federal and subnational taxes

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 20 October 2023

EY Cross-Border Taxation Alerts

Play Episode Listen Later Oct 20, 2023 4:46


A review of the week's major US international tax-related news. In this edition: US will not sign MLC on BEPS Pillar One Amount A in 2023, further negotiations required – Treasury, IRS officials offer international tax guidance update, including FTCs, CAMT – IRS to expand PLRs to majority of subchapter C transactions – US House and Senate introduce ‘U.S.-Taiwan Expedited Double Tax Relief Act'.

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 13 October 2023

EY Cross-Border Taxation Alerts

Play Episode Listen Later Oct 13, 2023 3:56


A review of the week's major US international tax-related news. In this edition: OECD/G20 IF releases Multilateral Convention to Implement Amount A of Pillar One – US Treasury requests comments on Amount A Pillar One MLC – Senate Finance Committee leaders urge USTR to warn Canada of consequences of enacting DST.

From page to practice
Series 5 Episode 15 - Isabelle Jones

From page to practice

Play Episode Listen Later Oct 8, 2023 51:12


In this episode I speak to Isabelle Jones about ResearchEd, supporting ITTs and being evidence informed.   If you'd like to support the podcast you can subscribe, share with colleagues or even visit www.buymeacoffee.com/fptppod   To subscribe to the From Page to Practice newsletter visit: http://eepurl.com/isnVYs and past issues can be viewed https://us21.campaign-archive.com/home/?u=00087e04e78053cbbe16431f6&id=89f24e0f82   For more information and to sign up to participate, visit: https://learninglinguist.co.uk/pagepracticepodcast/

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 6 October 2023

EY Cross-Border Taxation Alerts

Play Episode Listen Later Oct 6, 2023 5:04


A review of the week's major US international tax-related news. In this edition: Continuing resolution funds US government through 17 November, House Speaker ousted – IRS issues proposed cross-border triangular reorganization regulations – US, Israel sign CA agreement to share CbC reports – OECD/G20 Inclusive Framework adopts Multilateral Convention to implement BEPS Pillar Two STTR.

Ernst & Young ITS Washington Dispatch
EY ITTS Washington Dispatch, September 2023

Ernst & Young ITS Washington Dispatch

Play Episode Listen Later Oct 6, 2023 13:46


A monthly review of US international tax-related developments. In this edition: US Senate Finance Committee approves US-Taiwan tax bill – House Republicans want countries to delay BEPS Pillar Two, adopt GILTI-like regime – Senate Finance Committee considers IRS Chief Counsel pick – IRS publishes additional interim guidance clarifying CAMT – IRS announces intent to issue proposed regulations for Section 174, would affect cost sharing arrangements – US Government considering extension of temporary FTC relief, guidance on taxes paid under BEPS Pillar Two – IRS official offers international regulatory update – IRS CAP program accepting new applications – IRS announces major new compliance initiative targeting large partnerships.

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 29 September 2023

EY Cross-Border Taxation Alerts

Play Episode Listen Later Sep 29, 2023 2:55


A review of the week's major US international tax-related news. In this edition: US Congress seeks consensus on continuing resolution to fund government past FY deadline – Senate Finance Committee holds hearing on IRS Chief Counsel nomination – House Ways and Means Committee members warn against Canada's DST proposal.

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 22 September 2023

EY Cross-Border Taxation Alerts

Play Episode Listen Later Sep 22, 2023 3:33


A review of the week's major US international tax-related news. In this edition: US House budget negotiations continuing – House Republican tax writers want countries to delay BEPS Pillar Two implementation, urge rules similar to US GILIT regime – US Senate Finance Committee hearing to consider new IRS Chief Counsel – US tax treaty negotiations with Switzerland in latter stages, discussions with Israel – US continues to prefer “Alternative A” in scoping rules for Amount B in BEPS Pillar One

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 15 September 2023

EY Cross-Border Taxation Alerts

Play Episode Listen Later Sep 15, 2023 6:57


A review of the week's major US international tax-related news. In this edition: Senate Finance Committee approves Taiwan tax bill – IRS issues further interim CAMT guidance – IRS considering extending temporary foreign tax credit relief, BEPS Pillar Two-related FTC guidance in the works – IRS official offers preview of coming international tax guidance.

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 8 September 2023

EY Cross-Border Taxation Alerts

Play Episode Listen Later Sep 8, 2023 4:44


A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee delegation meets with OECD officials on BEPS 2.0 – IRS opens CAP program for 2024 tax year – IRS announces major new compliance initiative focused on large partnerships, corporations, high-income taxpayers and “promoters abusing tax rules on the books.” 

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 31 August 2023

EY Cross-Border Taxation Alerts

Play Episode Listen Later Sep 5, 2023 3:46


A review of the week's major US international tax-related news. In this edition: US delegation to meet with OECD BEPS officials – OECD likely to simplify global minimum tax information filings – UN issues final report on international tax cooperation – IRS Chief Counsel nomination expected to be on Senate Finance Committee agenda.

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 25 August 2023

EY Cross-Border Taxation Alerts

Play Episode Listen Later Aug 25, 2023 4:24


A review of the week's major US international tax-related news. In this edition: US Congress returns from August recess after Labor Day – IRS releases proposed regulations on digital asset information reporting – IRS extends FATCA penalty relief for certain dividend equivalent payments – IRS releases Q4 update to 2022-2023 Priority Guidance Plan.

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 18 August 2023

EY Cross-Border Taxation Alerts

Play Episode Listen Later Aug 18, 2023 2:23


A review of the week's major US international tax-related news. In this edition: IRS announces option to electronically request relief for certain late-filed international documents and forms – Treasury FinCEN rule to extend beneficial ownership information reporting deadline closer to release – OECD official reports open issues re BEPS Pillar One Amount A in upcoming MLC close to resolution.

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 11 August 2023

EY Cross-Border Taxation Alerts

Play Episode Listen Later Aug 12, 2023 4:20


A review of the week's major US international tax-related news. In this edition: Biden signs US-Taiwan Trade Agreement Act – Russia suspends tax treaties with US and other countries – UN report suggests alternative options to promote international tax cooperation.

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 4 August 2023

EY Cross-Border Taxation Alerts

Play Episode Listen Later Aug 4, 2023 4:33


A review of the week's major US international tax-related news. In this edition: Congress begins August recess, House Ways and Means tax bill fails to reach floor – Senate Finance Committee announces it will mark-up US-Taiwan tax legislation in September – IRS issues proposed consolidated return regulations – OECD will address BEPS 2.0 Pillar Two arbitrage tax planning.

EY Cross-Border Taxation Alerts
EY Cross-Border Taxation Spotlight for Week ending 28 July 2023

EY Cross-Border Taxation Alerts

Play Episode Listen Later Jul 28, 2023 3:44


A review of the week's major US international tax-related news. In this edition: US Treasury provides welcome temporary relief from controversial foreign tax credit regulations – IRS formalizes fast-track corporate PLR requests.