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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Where There's a Will, There's a Ways & Means

September 29, 2021

Episode 12-2021 | The engines of international tax change continue to chug along as we approach a final reconciliation bill. In this episode, we turn to the international tax proposals in the “Build Back Better Act” recently released by the House Ways and Means committee. [50:57]

Whither Wyden? Discussing the Discussion Draft

September 3, 2021

Episode 11-2021 | There are many paths to tax nirvana. This podcast unpacks the legislative text in Senator Wyden’s discussion draft released last week and can help you understand how it fits in with the journey to tax reform. [37:21]

ESG, OMG – The Intersection of Tax and the ESG Movement

August 13, 2021

Episode 10-2021 | It’s one of the hottest watchwords in investing – ESG. In this episode, we help you put "environmental, social, and corporate governance" in perspective by explaining what it is, how it has changed the investing landscape, and why companies’ tax function should care. [31:22]

Between Two Pillars, Part Deux: Consensus or Contentious?

July 26, 2021

Episode 09-2021 | In April, we explored the OECD’s two-pillar approach to the challenges of the digital economy and the global movement to coordinate taxation of multinational enterprises. This podcast discusses the recent agreement by the G20 and the OECD Inclusive Framework on the two pillars and examines the many obstacles, political and technical, that the OECD must overcome to turn this agreement into reality. [38:34]

Red Light, Green Book: The Anti-Inversion Proposals

June 30, 2021

Episode 08-2021 | Part 3 of our series on the Biden administration’s Green Book delves into its sweeping new anti-inversion provisions. Amid continued concern with U.S.-based companies inverting into foreign jurisdictions, the Green Book resurrects the ghosts of past proposals to tighten the screws still further. This podcast describes the potential impact of these provisions on acquisitions of U.S.-based companies. [31:53]

Green Green Grass of Home: The Outbound Perspective of the Green Book

June 22, 2021

Episode 07-2021 | In part 2 of our series on the Biden administration’s Green Book, the focus shifts to outbound provisions. The TCJA resulted in dramatic changes to the tax landscape for U.S. multinationals, and the Green Book proposes more. This podcast walks you through the Green Book’s outbound proposals—in particular GILTI regime changes—and describes potential ramifications for U.S.-based multinationals. [43:28]

Greener on the Other Side? The Inbound Perspective of the Green Book

June 15, 2021

Episode 06-2021 | After much anticipation, the Biden administration showed its cards in the General Explanations of the Administration’s Fiscal Year 2022 Revenue Proposals (Treasury’s Green Book), which provided beach reading for tax professionals over Memorial Day weekend. This podcast walks through the Green Book’s SHIELD and disproportionate interest limitation proposals and how they might affect inbound companies. [40:59]

State of Play: State Taxation of Foreign Income After the TCJA

May 24, 2021

Episode 05-2021 | Multinational companies potentially face a labyrinth of state and local taxation in addition to the already-complex federal tax issues. This podcast delves into the various ways in which states correspond to—and diverge from—the federal taxation of cross-border income streams and examines how these intricacies may affect companies as they deal with TCJA and potential Biden Administration changes. [24:15]

Between Two Pillars: The U.S. at the OECD

April 28, 2021

Episode 04-2021 | There’s plenty of activity on the domestic front in terms of international tax reform. And, it’s all taking place in the context of a wider global movement to coordinate the taxation of multinational enterprises. This podcast explores the latest OECD action on Pillars One and Two and considers how aspects of these proposals relate to current proposals in the White House “Made in America Tax Plan.” [31:14]

Tax Reform Rewind: The White House and The White Paper

April 13, 2021

Episode 03-2021 | The dust hasn’t even settled on the TCJA, and yet all eyes are on tax reform…again. President Biden has issued his “Made in America Tax Plan” and Senator Wyden his “Overhauling International Taxation” whitepaper—both with significant changes to the GILTI, FDII, and BEAT regimes. This podcast explores what another major revision to the U.S. international tax system may mean to taxpayers. [26:13]

SPAC, Eggs, SPAC, SPAC, Bacon, and SPAC

April 6, 2021

Episode 02-2021 | SPACs—also known as a “blank check companies”—have become a staple investment vehicle. This podcast discusses the recent explosion of SPAC IPOs and the common U.S. international tax issues that arise in the context of SPAC transactions, particularly the application of the U.S. inversion rules and the rules related to the taxation of shareholders in PFICS. [36:17]

IP, Where Art Thou?

March 22, 2021

Episode 01-2021 | In a world shaped by the OECD’s BEPS initiative and the TCJA, the traditional considerations for locating a company’s intellectual property (IP) are changing. This podcast discusses a number of the potential U.S. federal and foreign tax issues that drive decision-making for the location of IP and research and development facilities. [27:27]