Inside International Tax
In the Inside International Tax podcast series, you'll hear from KPMG professionals about U.S. international tax and OECD-related tax guidance and gain concise, practical insights about the impact on multinational enterprises.
- Update frequency
- every 29 days
- Average duration
- 32 minutes
- Episodes
- 55
- Years Active
- 2021 - 2025
MAP Quest: A Conversation with Doug O'Donnell on Cross-Border Dispute Resolution
Doug O'Donnell joins the podcast to explore how the Mutual Agreement Procedure (MAP), a treaty-based process for resolving double taxation disputes between countries, operates at the IRS and internat…
00:32:56 |
Wed 03 Sep 2025
From the OB3 to the OECD: What Does the G7 Agreement Mean for Pillar Two?
In this episode of Inside International Tax, we discuss what the implications of the 'side-by-side' solution agreed to by the G7 are, and how this solution impacts U.S. parented groups and the viabil…
00:30:14 |
Thu 31 Jul 2025
Reconcilable Differences: On the International Tax Provisions in the OB3
What are the key international tax provisions included in the One Big Beautiful Bill Act, and how could these provisions alter the U.S. international tax landscape?
The One Big Beautiful Bill Act ma…
The One Big Beautiful Bill Act ma…
00:32:24 |
Wed 16 Jul 2025
Revenge of the Smith: On the Retaliatory Measures in the OB3
What are the key implications of the 'revenge tax' of section 899 in the 'One Big Beautiful Bill,' and which taxpayers should be concerned?
In this episode, we explore how proposed section 899 aims …
In this episode, we explore how proposed section 899 aims …
00:27:03 |
Thu 05 Jun 2025
The Art of the Global Tax Deal: The US Negotiates with the OECD on Pillar Two
What concessions are the United States seeking from the OECD's Inclusive Framework on the Pillar Two regime and how might they protect U.S. multinationals from over-taxation?
In this episode, we dis…
In this episode, we dis…
00:17:55 |
Thu 08 May 2025
Clear Skies Ahead or Storm on the Horizon? Navigating the New Digital Content and Cloud Regulations
What should taxpayers know about the digital content and cloud regulations, and how should they prepare for their impact?
In this milestone 50th episode of the podcast, we explore the key changes in…
In this milestone 50th episode of the podcast, we explore the key changes in…
00:37:40 |
Thu 03 Apr 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 objecti…
00:32:56 |
Fri 07 Mar 2025
From Taxed to Tracked - Navigating the Complexities of the Proposed PTEP Regulations
In this episode, we explore the key concepts of the recently proposed previously taxed earnings and profits, PTEP, regulations and their practical impact on taxpayers.
Join us as our host Gary Scanl…
00:38:43 |
Wed 05 Feb 2025
Let's Get Digital - Value Chain Planning Opportunities Amidst Digital Transformation
In this episode, we explore the basics of digital transformation and value chain management, focusing on how digital intangibles and digital technologies are becoming increasingly important to taxpay…
00:23:25 |
Wed 08 Jan 2025
I'm Just a (Reconciliation) Bill: How the Election Could Shape U.S. and Global Tax Policy
In this episode, we discuss how the results of the November election in the United States may impact tax policy in the near term, including the ways in which the new Congress may be able to pass tax …
00:33:33 |
Wed 04 Dec 2024
A Dual-Edged Sword: Exploring the Proposed DCL Regulations
In this episode, we explore the most critical aspects of the proposed dual consolidated loss, DCL, regulations, including how a DCL used in computing a Pillar Two GloBE liability could be a 'foreign …
00:29:10 |
Tue 05 Nov 2024
CAMT-astic or CAMT-astrophe? Making Sense of the International Tax Provisions in the Proposed CAMT Regulations
In this episode, we discuss the international tax provisions in the recently released proposed CAMT regulations, including how the proposed regulations expand the reach of the special scoping rule fo…
00:28:16 |
Tue 15 Oct 2024
All About that Baseline: Preparing for a Future with Amount B
With the implementation of Amount B potentially around the corner, in this episode we explore Amount B, its impact on taxpayers, the cadence and contour of its global roll-out, and any lingering issu…
00:27:40 |
Tue 03 Sep 2024
Chevron Unleaded: The Supreme Court Takes the Wheel
In this episode, we dive into the Supreme Court's recent decision in Loper Bright Enterprises v. Raimondo to overturn Chevron v. Natural Resources Defense Council, which set out the existing framewor…
00:32:17 |
Wed 31 Jul 2024
A Tale of Two Pillars, Part II: A Discussion with Michael Plowgian on the Current State of Pillar Two
In this episode, we are joined by Michael Plowgian, formerly the Deputy Assistant Secretary for International Tax Affairs at Treasury, to discuss the rapid global progress in Pillar Two enactment, th…
00:29:44 |
Wed 26 Jun 2024
A Tale of Two Pillars, Part I: A Discussion with Michael Plowgian on the Current State of Pillar One
In this episode, we are joined by Michael Plowgian, formerly the Deputy Assistant Secretary for International Tax Affairs at Treasury, to explore the fundamental shift in cross-border taxation that P…
00:25:07 |
Fri 07 Jun 2024
Funding the Flames: Why Foreign Multinationals Must Take Stock of the Stock Buyback Excise Tax
In this episode, we explore how the recently issued proposed regulations addressing the stock buyback excise tax can impact foreign multinationals, how they both limit and broaden the scope of the fu…
00:25:41 |
Thu 02 May 2024
Put Your Best FEEP Forward: Preparing for the New Section 987 Regulations
In this episode, we explore the newest set of proposed section 987 regulations, including how they have evolved in the decades since the first proposals and what taxpayers should be thinking about no…
00:26:16 |
Thu 07 Mar 2024
Notice 2023-80: FTCs, DCLs, and the GloBE Rules, Oh My!
What guidance does Notice 2023-80 provide regarding the interaction of the GloBE rules with both foreign tax credits and dual consolidated losses and what questions still remain?
00:27:28 |
Thu 08 Feb 2024
More on Moore: Unpacking the Recent Oral Arguments in the Moore Case
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?
00:24:41 |
Tue 19 Dec 2023
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