Inside International Tax

Inside International Tax, a KPMG TaxRadio podcast series, features insights into current international tax trends and developments. In these podcasts, KPMG professionals discuss U.S. international tax and OECD-related tax guidance and provide concise, practical insights about the impact on multinational enterprises.

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March 7, 2025 | Duty Bound: How Tariffs Could Reshape the Tax Landscape

In this episode of Inside International Tax, we delve into the tariffs recently announced by the Trump administration, exploring the president's authority to impose them, the potential policy objectives behind their use, and the impact they could have on taxpayers and trade partners.

March 7, 2025

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February 6, 2025 | From Taxed to Tracked - Navigating the Complexities of the Proposed PTEP Regulations

In this episode of Inside International Tax, we explore the key concepts of the recently proposed previously taxed earnings and profits (PTEP) regulations and their practical impact on taxpayers.

February 6, 2025

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January 8, 2025 | Let’s Get Digital with Value Chain Management

In this episode of Inside International Tax, we explore the basics of digital transformation and value chain management, focusing on how digital intangibles and digital technologies are becoming increasingly important to taxpayers in creating value and optimizing tax outcomes.

January 8, 2025

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December 5, 2024 | I’m Just a (Reconciliation) Bill

In this episode of Inside International Tax, we look at what impact the 2024 Presidential and Congressional elections will have on U.S. tax policy, and what role the 2025 "tax cliff "and global tax reform will play in shaping that policy.

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November 6, 2024 | A Dual-Edged Sword: Exploring the Proposed DCL Regulations

What's new? How do they interact with Pillar Two Globe rules? What is the impact on taxpayers addressing intercompany transactions?

November 6, 2024

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October 15 , 2024 | CAMT-astic or CAMT-strophe? Making Sense of the Proposed Regulations

What complexities and challenges can taxpayers expect from the international tax provisions of the recently released Corporate Alternative Minimum Tax (CAMT) proposed regulations, and how might the proposed regulations resolve or exacerbate existing issues?

October 15, 2024

/exploring-transfer-pricing
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September 3, 2024 | All About that Baseline: Preparing for a Future with Amount B

What is the future of Pillar One’s Amount B, its potential impact on taxpayers, and the issues with Amount B that remain to be resolved at the OECD?

September 3, 2024

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July 31, 2024 | Chevron Unleaded: The Supreme Court Takes the Wheel

Inside International Tax podcast: How will the Supreme Court decision in Loper Bright Enterprises v. Raimondo impact the tax regulatory landscape?

July 31, 2024

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June 26, 2024 | A Tale of Two Pillars, Part II

Inside International Tax podcast: A Discussion with Michael Plowgian on the Current State of Pillar Two

June 26, 2024

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June 6, 2024 | A Tale of Two Pillars, Part I

Inside International Tax podcast: A Discussion with Michael Plowgian on the Current State of Pillar One

June 6, 2024

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May 1, 2024 | Funding the Flames: Why Foreign Multinationals Must Take Stock of the Stock Buyback Excise Tax

Inside International Tax podcast: How would new proposed regulations apply the stock buyback excise tax to foreign- multinationals?

May 1, 2024

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March 7, 2024 | Put Your Best FEEP Forward: Preparing for the New Section 987 Regulations

Inside International Tax: What can taxpayers do today to be ready for the expected finalization of the section 987 regulations?

March 7, 2024

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February 08, 2024 | Notice 2023-80: FTCs, DCLs, and the GloBE Rules, Oh My!

What guidance does Notice 2023-80 give regarding the interaction of GloBE rules with foreign tax credits and dual consolidated losses?

February 8, 2024

February 08 2024 | Notice 2023-80: FTCs, DCLs, and the GloBE Rules, Oh My!
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December 18, 2023 | More on Moore: Unpacking the Recent Oral Arguments in the Moore Case

Inside International Tax podcast: What can be gleaned from the oral arguments before the Supreme Court in Moore v. United States on the constitutionality of the mandatory repatriation tax?

December 18, 2023

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November 13, 2023 | Cross-Border CAMT: Unpacking the International Aspects of the New IRS Notice

Inside International Tax podcast: Exploring the international tax aspects of Notice 2023-64, which provides interim guidance on CAMT.

November 15, 2023

November 13, 2023 | Cross-Border CAMT: Unpacking the International Aspects of the New IRS Notice
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October 4, 2023 | Pillar Two Reloaded: Second Round of OECD Guidance

Podcast: What guidance was released in the second round of OECD Pillar Two guidance and where do we stand on the implementation of GloBE rules?

October 4, 2023

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August 23, 2023 | If I(RS) Could Turn Back Time: Notice 2023-55 Offers FTC Creditability Rules Relief

Podcast: What is the scope of the temporary relief being offered to taxpayers by Notice 2023-55 and what lies ahead for the final foreign tax credit regulations?

August 23, 2023

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July 27, 2023 | Moore than Words: Supreme Court Grants Cert on Section 965 Challenge

Podcast: What are the potential ramifications from the Supreme Court’s decision to hear the section 965 challenge in Moore? What should taxpayers consider doing now?

July 27, 2023

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June 28, 2023 | Ready, Set, GloBE!

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

June 28, 2023

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May 24, 2023 | Homeward Bound: The Intangible Journey

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

May 24, 2023

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April 19, 2023 | Around the GloBE: Tracking the Pillar Two Rules’ Progress

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

April 19, 2023

Around the GloBE: Tracking the Pillar Two Rules’ Progress
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March 29, 2023 | I Literally CAMT: Dealing with Your International Min Tax Issues

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

March 29, 2023

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March 29, 2023 | I Literally CAMT: Dealing with Your International Min Tax Issues

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

March 29, 2023

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March 1, 2023 | CAMT RuM&Ations: Exploring the Impact of Notice 2023-7 on Transactions

Podcast discusses Notice 2023-7 and its impact on the corporate alternative minimum tax treatment of M&A transactions

March 1, 2023

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February 1, 2023 | What to Expect when You’re Expecting Pillar Two

Podcast discusses when U.S. multinationals can expect the GloBE rules to come on line and how those rules may impact them

February 1, 2023

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December 16, 2022 | Credit Repair: Do the Proposed Foreign Tax Credit Regulations Do Enough?

Podcast: How helpful are the proposed FTC regulations in determining the creditability of corporate income taxes and royalty withholding taxes of many of our major trading partners?

December 16, 2022

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October 5, 2022 | A Done Deal: How M&A Today Can Impact Your GloBE Liability Tomorrow

Podcast: What GloBE rules should you consider in structuring M&A transactions today?

October 5, 2022

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August 16, 2022 | CAMT Stop, Won’t Stop: Corporate AMT under the Inflation Reduction Act

Podcast: What do you need to know to prepare for the new corporate AMT?

August 16, 2022

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August 3, 2022 | Ripple FX: The U.S. Tax Impact of a Strong U.S. Dollar

Podcast: What are the U.S. tax implications of the recent strengthening of the U.S. dollar?

August 3, 2022

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February 1, 2022 | The Credit Crunch: Exploring the Impact of the Final Foreign Tax Credit Regulations

Inside International Tax, Episode 02-2022 | How will the new foreign tax credit rules affect creditability of foreign taxes?

February 1, 2022

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October 4, 2023 | Pillar Two Reloaded: Second Round of OECD Guidance

Podcast: What guidance was released in the second round of OECD Pillar Two guidance and where do we stand on the implementation of GloBE rules?

October 4, 2023

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