Destination Country X

Destination Country X, a KPMG TaxRadio podcast series, features current tax and trade developments affecting cross-border business. Professionals from KPMG in the United States and KPMG International member firms discuss potential benefits and practical challenges for multinational enterprises and provide insights to help you navigate the investment landscape.

Hosted by

Kimberly Majure

Principal, International Tax & Legal Operations Transformation Services, KPMG US

Kortney Wallace

Principal, International Tax, KPMG US

Podcasts

U.S. FTCs and Brazil’s Tax Developments (Part 2): Timing Is Everything

December 21, 2022

Episode 09-2022 | Just before Thanksgiving, the U.S. Treasury and IRS published proposed foreign tax credit (FTC) regulations. While U.S. multinationals may be thankful for the proposals' additional flexibility, how much they actually help, particularly with respect to Brazilian income and withholding tax developments, is unclear. This podcast discusses of the potential impact of these possible changes. [32:59]

Brazil Tax Developments (Part 1): The More Things Change ...

November 30, 2022

Episode 08-2022 | Once again, Brazil has important tax proposals on the table. But this time, instead of embedding them in a big package, the administration has tabled a few, more targeted ideas. And while one (in the tax controversy space) is quite taxpayer-favorable, the other (on dividend withholding) … not so much. This podcast discusses these proposals and their potential implications for multinational companies. [22:37]

Chile's Tax Reform: Evolution or Revolution?

October 12, 2022

Episode 07-2022 | Just a few months into Chilean President Gabriel Boric's administration, Chile has not only seen a constitutional referendum, but also a major tax reform proposal that would convert the country to a classical tax system. Along with that change are proposals regarding the corporate tax rate, NOL limitations, FTCs, and more. This podcast examines these potential tax reforms in Chile. [25:30]

A Min Tax by Any Other Name

September 12, 2022

Episode 06-2022 | For the last several years, Min Tax has been a favorite pastime of international tax folk everywhere. Pillar 2 and GILTI, BEAT, and SHIELD featured in the discussion, and now enter the new U.S. Book Min Tax. This podcast explores this new Min Tax and its potential implications for in-scope multinationals. [25:27]

Mexico’s Transfer Pricing Developments: Addition by Subtraction?

August 9, 2022

Episode 05-2022 | This podcast reviews recent developments in Mexico—the termination of the maquiladora advance pricing agreement program and 2021 Mexico tax reform rule changes that stepped up the scope and timing of transfer pricing compliance—affecting transfer pricing and examines how taxpayers are dealing with these changes and what Mexico may do next. [25:05]

Brazilian Transfer Pricing Developments: One Giant Step?

June 2, 2022

Episode 04-2022 | Brazil has announced expectations for a new transfer pricing system. U.S. taxpayers facing challenges in fitting Brazil’s current rules into the new U.S. foreign tax credit rules are breathing sighs of relief. But … there’s a long way to go to secure creditability of Brazilian taxes. This podcast looks at what’s been said, what has not, and what it all may mean for taxpayers with Brazilian operations. [26:13]

U.S. Economic Sanctions: Trade & Tax Impacts for Russian Business Activity

May 13, 2022

Episode 03-2022 | In this episode, KPMG Trade & Customs professionals discuss the practical implications for companies trying to comply with the U.S. economic sanctions against Russia, and International Tax professional outline some of the U.S. federal income tax issues faced by companies with operations in Russia. [21:13]

U.S. Forced Labor Rules: Targeting Kinks in Your Supply Chain

March 21, 2022

Episode 02-2022 | Forced labor rules, which prevent the import of goods made with forced labor, have recently become an instrument of change for human rights. The U.S. government, civil society, and American consumers are demanding that companies ensure ethical behavior in their supply chains. This podcast looks the challenges companies face in trying to demonstrate good behavior. [29:51]

EU OK on CbC ESG: What Does That Spell for MNEs?

February 18, 2022

Episode 01-2022 | For several years, the European Union’s ambitious public country-by-country reporting agenda has been an on-again, off-again affair—and one arguably more “off” than “on.” But with Portugal driving the EU agenda, we finally have resolution. This podcast provides an update on this development and discusses the potential implications for multinational enterprises. [24:33]

Archived episodes 2021

BEPS 2.0 in LATAM: Implications and Complications

December 21, 2021

Episode 14-2021 | Anticipated BEPS 2.0 changes will affect all adopting Inclusive Framework members, but do we actually understand how? In this podcast, the potential implications of Pillars One and Two in a number of countries in Latin America—Costa Rica, Mexico, Panama, and Uruguay—are discussed. [31:24]

Colombia: Parable of a Reform

November 23, 2021

Episode 13-2021 | Many considerations shape and color a country’s decision to pursue tax reform. Fiscal concerns, taxpayer equity, investment incentives, and global competitiveness are typical issues. With BEPS 2.0, these factors seem overshadowed by the drive for global harmonization. Listen to this podcast for an update on Colombian tax reform efforts and learn how the current environment is affecting efforts there. [20:29]

Tax 2.0: Pillars to Post on BEPS and U.S. Tax Reform

November 12, 2021

Episode 12-2021 | It’s taken a bit—time, effort, and diplomatic magic—but with almost all of the Inclusive Framework on board, Pillars 1 and 2 are on the near horizon. Listen to this podcast to learn where things stand on the global stage? which jurisdictions stand to win big and which ones not so much? and how, as a practical matter, is this going to work out in the United States? [18:21]

It’s That Time of Year Again: Mexico’s 2022 Tax Reform

October 29, 2021

Episode 11-2021 | On October 26, 2021, Mexico’s Congress approved a tax reform package that includes no new taxes or rate increases. Still, the legislation contains provisions that could spell an effective tax rate increase for U.S. multinationals with Mexican operations. Listen to this podcast to learn about new restrictions for intercompany financing, termination of the maquiladora APA program, and VAT rule changes. [27:39]

“Made in America”: Biden Trade Policy Update

October 5, 2021

Episode 10-2021 | 2021 started off with a pair of Executive Orders on U.S. trade issues—signals of an administration in hot pursuit of a pro-America trade agenda and in making Buy American “real.” But the path for tariffs has been less straightforward. This podcast provides updates on efforts to secure critical U.S. supply chains, section 301 tariff exclusions, and enforcement activities in the forced labor arena. [23:27]

Brazilian Tax Reform: Are We There Yet?

September 14, 2021

Episode 09-2021 | There’s been quite a lot of talk about Brazilian tax reform—including whether it’s going to happen. But if enacted, the current tax reform proposals would go into effect January 1, 2022. This podcast discusses features of the proposed legislation that could significantly change the landscape for U.S. multinational investment and the political pressures that inform likelihood of success. [23:08]

“Value” by Any Other Name: Tax, Pay Equity, and Employee Value

August 6, 2021

Episode 08-2021 | Lisa Cabel (KPMG Law in Canada) and Julie Kushner (KPMG Value Chain Management in the United States) join podcast hosts Kim Majure and Kortney Wallace to discuss the Canadian pay equity rules’ approach to determining employee value and the tax implications, considering the rethinking of the global tax architecture under BEPS 2.0 and the ESG push to think more broadly about the value of people. [22:38]

Between a Rock and a Hard Place: BEAT vs. SHIELD

July 23, 2021

Episode 07-2021 | Podcast hosts Kimberly Majure and Kortney Wallace sit down with Peter Uebelhart and Jennifer Sponzilli with the KPMG U.S. Switzerland Corridor group to discuss the competitive pressures the proposed SHIELD would put on foreign-based multinational groups with U.S. operations. [21:35]

The DST “Trade Off”: The Biden Administration’s Balancing Act

May 18, 2021

Episode 06-2021 | By now we are no strangers to the tax versus trade dynamic. And while we are hearing a shift in tone from the new administration, the overall themes sound very much the same. America first but... friendly? This podcast explores where we are on the trade and customs front and where we seem to be going. [20:44]

Mexico's Labor Reform Redux

April 28, 2021

Episode 05-2021 | Last fall, a labor reform initiative, which would treat intercompany services companies as illegal and force restructuring of many Mexican operations, was making its way through Mexico’s Congress. After some delays, new rules have hit and go into effect on May 1, 2021. This podcast discusses the rules, noting that companies will have three months to restructure or face stiff labor and tax sanctions. [19:06]

Public Country-by-Country Reporting: Opening Pandora’s Box

April 15, 2021

Episode 04-2021 | When the OECD’s country-by-country reporting (CbCR) framework first surfaced, tax authorities took pains to ensure that, to the extent possible, taxpayer information was used appropriately and kept confidential. Then the EU raised the possibility of public CbCR for multinational groups with EU operations. This podcast examines the current state of the recently resurfaced debate. [19:37]

Brexit Finally Here! (Did You Miss It?)

March 18, 2021

Episode 03-2021 | Since the United Kingdom’s 2016 referendum to exit the European Union, we have observed Brexit in sound bites. And while we’ve known it was coming, it still seemed to sneak up on us at the end. This podcast examines expected and unexpected practical challenges the arrival of Brexit has posed for U.K. companies and others doing business with them. [19:03]

Mexico and Argentina Mandatory Disclosure Rules Revisited

March 1, 2021

Episode 02-2021 | Both Mexico and Argentina introduced mandatory disclosures rules last year. The expectation was that, as more guidance was issued, the path for compliance would grow clearer. As it turns out, this has not necessarily been the case. This podcast examines recent developments, practical challenges, early insights, and open issues. [19:40]

Archived episodes 2020

Cross-Border Highlights of the Biden Tax Plan, Chapter 2

December 22, 2020

Episode 07-2020 | Post-election (but before Senate control has been determined), this podcast examines a range of potential tax and trade legislative and regulatory developments under the incoming Biden Administration: repeal or modification of TCJA tenets, proposed onshoring tax credit, implications for U.S. competitiveness, IRS and CBP funding, and public country-by-country reporting. [17:01]

Argentina’s Mandatory Disclosure Rules: Limited Time, Limited Guidance, Immediate Effect

December 16, 2020

Episode 06-2020 | Argentina published its mandatory disclosure rules on October 20, 2020, with immediate effect. The rules, including the 10-business-day reporting requirements, are not self-executing; specific compliance details are yet to be released. This podcast focuses on the challenges taxpayers are facing in light of the new (yet incomplete) MDR rules. [16:05]

Mexico's New Labor Proposals and Tax Implications for Mexican Operations

December 7, 2020

Episode 05-2020 | New labor proposals in Mexico—which, if passed, could go into effect early next year—have been introduced to protect workers’ labor and social security rights. Listen to this podcast to learn why and how the structure of Mexican operations may need to change. [19:48]

Mexico’s Mandatory Disclosure Rules – Are You Prepared?

November 5, 2020

Episode 04-2020 | While the EU’s DAC6 mandatory disclosure regime (MDR) and its delayed implementation has been the subject of significant discussion, less is known about Mexico’s MDR, which begins January 1, 2021. This podcast discusses the similarities and differences between Mexico's MDR and DAC6 as well as what companies should be doing to prepare for compliance. [16:56]

Cross-Border Trade Disruption: Tariff vs. Tax?

October 31, 2020

Episode 03-2020 | Recent tariff and digital services tax (DST) activity has affected cross-border trade, sometimes in unexpected ways. This podcast looks at U.S. protective tariff actions, how DST developments have become intertwined with these actions, and the interaction between the interaction between the U.S.-Mexico-Canada Agreement and Mexico’s new digital VAT. [15:58]

Cross-Border Highlights of the Biden Tax Plan

October 12, 2020

Episode 02-2020 | The Biden tax plan includes pieces that may affect multinational enterprises, and some cross-border issues have not yet been addressed by Candidate Biden. This podcast discusses the minimum tax, GILTI, and anti-round tripping proposals, what may happen with the FDII and BEAT regimes, how the BEPS 2.0 initiatives may be addressed, and the use of taxes versus tariffs. [16:02]