Our Inside International Tax 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.
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]
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]
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]
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]
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]
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]
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]
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]