Inside International Tax KPMG LLP (U.S.)
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- Business
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.
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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 Pillar One represents and to update us on the status of Amounts A and B, the hurdles that still exist for implementation, and the United States' current negotiating position with respect to Pillar One
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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 funding rule first introduced by Notice 2023-2, and what foreign multinationals should be doing now to ready themselves for the excise tax.
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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 now as we await finalization.
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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?
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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?
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Cross-Border CAMT: Unpacking the International Aspects of the New IRS Notice
Exploring the international tax aspects of Notice 2023-64, which provides interim guidance on CAMT.