Inside International Tax

KPMG LLP (U.S.)

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.

  1. 6 DAYS AGO

    Sovereign Immunity: How Recent Regs Redraw the Lines for the Section 892 Exemption

    In this episode, we explore the evolving landscape for sovereign wealth and foreign government pension funds under section 892, highlighting the latest regulatory developments, practical implications for asset managers, and how new guidance is shaping investment strategies and compliance for global investors in the U.S. market. Join us as our co-hosts Gary Scanlon and Kristen Gamboa interview Dan Winnick (Principal, KPMG Washington National Tax - International Tax), and Kirstin Gallagher (Principal, KPMG International Tax - Financial Services Group and US Tax Leader for Sovereign Wealth and Pension Funds), to answer these questions and more.

    28 min

  2. 13 JAN

    Pillar Two Side-by-Side: Has the OECD Finally Found Its Stride?

    In this episode, we examine the impact on US and foreign multinationals of the OECD's Side-by-Side Package, which includes the long-awaited Side-by-Side Safe Harbor and other guidance and safe harbors intended to reduce the compliance costs of the GloBE system and protect substance-based credits. Join us as our co-hosts Gary Scanlon and Kristen Gamboa interview Michael Plowgian (Co-Principal in Charge, KPMG Washington National Tax - International Tax), along with Conrad Turley (Tax Policy Leader and Chair of the Global Tax Policy Leadership Group - KPMG Global), and Alistair Pepper (Managing Director, KPMG Washington National Tax - Economic and Valuation Services) to answer these questions and more on the latest episode of Inside International Tax.

    39 min

  3. 06/11/2025

    The Interplay of OB3, BEAT, and CAMT: A Virtuous Cycle or Circular Firing Squad?

    In this episode of Inside International Tax, we examine how recent OB3 legislative changes - including changes to domestic R&E expenses, the reinstatement of 100 percent bonus depreciation, and modifications to section 163(j) and FDII - interact with BEAT and CAMT, and what these developments mean for taxpayers. Join us as our co-hosts Gary Scanlon and Kristen Gamboa interview Seevun Dunckzar (Managing Director, KPMG Washington National Tax - International Tax), to review these scenarios and more on the latest episode of Inside International Tax.

    31 min

  4. 30/09/2025

    A Conversation with Retiring Tax Principal Tom Zollo

    In this episode, Tom Zollo, Principal in the KPMG Washington National Tax - International Tax practice, shares insights from decades in transfer pricing and international tax structuring, reflects on recent tax changes, and offers advice for navigating today's evolving landscape as he prepares for retirement. Join us as our co-hosts Gary Scanlon and Kristen Gamboa interview Tom Zollo to cover these topics and more on the latest episode of Inside International Tax.

    21 min

  5. 03/09/2025

    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 internationally, the steps taxpayers should undertake to optimize outcomes, the complexities involved in negotiations between tax authorities, the practical challenges and trends affecting the MAP process, and alternatives to MAP for cross-border dispute resolution. Join us as our co-hosts Gary Scanlon and Kristen Gamboa interview Doug O'Donnell, formerly IRS Acting Commissioner and previously a participant in the OECD Forum on Tax Administration, to answer these questions and more on the latest episode of Inside International Tax.

    33 min

  6. 31/07/2025

    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 viability of Pillar Two. Join us as our co-hosts Gary Scanlon and Kristen Gamboa interview returning guest Michael Plowgian, a Principal in the KPMG WNT - International Tax practice, and Marcus Heyland, a Principal in the KPMG WNT - Economic and Valuation Services practice, to answer these questions and more on the latest episode of Inside International Tax.

    30 min

  7. 16/07/2025

    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 made significant changes to the GILTI, FDII, BEAT and foreign tax credit regimes. In this episode, we explore how these changes may have altered the U.S. international tax landscape. Join us as our co-hosts Gary Scanlon and Kristen Gamboa interview returning guest Ron Dabrowski, Principal in Charge of the KPMG Washington National Tax - International Tax group to answer these questions and more on the latest episode of Inside International Tax.

    32 min

  8. 05/06/2025

    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 to counteract unfair foreign taxes through specific retaliatory measures, its applicability and scope for taxpayers, and its potential future as it progresses to the Senate. Join us as our co-hosts Gary Scanlon and Kristen Gamboa interview returning guest Dan Winnick from the KPMG Washington National Tax - International Tax group to answer these questions and more on the latest episode of Inside International Tax.

    27 min
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About

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.

Information

  • Creator
    KPMG LLP (U.S.)
  • Years Active
    2021 - 2026
  • Episodes
    59
  • Rating
    Clean
  • Copyright
    © 2025 KPMG LLP, a Delaware limited liability partnership and a member firm of the KPMG global organization of independent member firms affiliated with KPMG Interantional Limited, a private English company limited by guarantee. All rights reserved. Any reproduction, distribution, or modification of this podcast or its content without KPMG LLP's permission is prohibited.
  • Show Website
    Inside International Tax

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