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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Homeward Bound: The Intangible Journey

May 24, 2023

Episode 05-2023 | In this episode, we explore the newly released section 367(d) proposed regulations addressing the repatriation of previously offshored IP, with respect to both the benefits of the relief offered and its limits. [28:06]

Around the GloBE: Tracking the Pillar Two Rules’ Progress

April 19, 2023

Episode 04-2023 | In this episode, we update you on the worldwide implementation of the GloBE rules, recent developments as jurisdictions continue to release draft legislation, and key aspects of transitional OECD administrative guidance released in February. [40:59]

I Literally CAMT: Dealing with Your International Min Tax Issues

March 29, 2023

Episode 03-2023 | In this episode, we explore the most pressing CAMT international tax issues for which taxpayers need guidance, including the treatment of CFC dividends, the credibility of foreign income taxes paid by partnerships, and the interaction between CAMT and the Pillar Two GloBE rules. [36:23]

CAMT RuM&Ations: Exploring the Impact of Notice 2023-7 on Transactions

March 1, 2023

Episode 02-2023 | Notice 2023-7 provided some much-needed initial guidance on the corporate alternative minimum tax (CAMT) consequences of M&A transactions, but it also raised more questions than it answered. This podcast discusses the notice and its potential impact on the CAMT treatment of M&A transactions. [38:05]

What to Expect when You’re Expecting Pillar Two

February 1, 2023

Episode 01-2023 | Have no doubt, Pillar Two is coming. This podcast looks at when U.S. multinationals can expect the global minimum tax (GloBE) rules to come on line and how those rules may impact them. [32:53]

2022 podcast episodes

Credit Repair: Do the Proposed Foreign Tax Credit Regulations Do Enough?

December 16, 2022

Episode 11-2022 | On November 18, Treasury and the IRS proposed changes to the final foreign tax credit regulations to address taxpayer concerns over some of the rules’ unintended consequences in rendering certain foreign income taxes and royalty withholding taxes noncreditable. This episode explores the effectiveness of the proposed changes in fixing these shortfalls and outlines actions taxpayers can be taking. [39:07]

A Done Deal: How M&A Today Can Impact Your GloBE Liability Tomorrow

October 5, 2022

Episode 10-2022 | The widespread implementation of the OECD’s Pillar Two Global Anti-Base Erosion (GloBE) rules is now a strong probability In this episode, we discuss the many pitfalls that these rules may present to taxpayers currently engaging in M&A transactions. [34:43]

The GloBE Rules: Bye Bye American Pie

March 15, 2022

Episode 04-2022 | In this episode, we turn back to the Pillar 2 GloBE rules and explore how these rules could deny U.S. multinationals the benefit of Congressionally sanctioned tax incentives. [34:35]

Capitalization Punishment: The New Rules of Section 174

February 17, 2022

Episode 03-2022 | Mandatory capitalization of R&E is here (for now). In this episode, we turn to this sleeper provision from the TCJA and unpack some of the international tax implications from the provision that might ripple through your financial statements and tax returns. [31:41]

Around the GloBE: Exploring the Pillar Two Model Rules

January 11, 2022

Episode 01-2022 | In late December, the OECD released model rules for a 15% global minimum tax, a component of the two-pillar approach to taxing the digital economy. In this episode, we cover the latest guidance on Pillar Two’s income inclusion rule and undertaxed payments rule (“GloBE rules”), the interaction of Pillar One and Pillar Two timelines, and the implementation implications of U.S. legislative (in)action. [33:26]

2021 podcast episodes

Back to Build Back Better Act: Doing the Bare Minimum

November 10, 2021

Episode 14-2021 | As the House progresses with the Reconciliation Bill, releasing a November 3 “manager’s amendment,” new proposals have surfaced. In this episode, we describe the notable changes and provide an update on the rapidly evolving legislative process. In particular, we focus on the corporate profits minimum tax proposal and what it could mean for multinational corporations. [32:57]

Between Two Pillars, Part 3: Mind the Gap

October 20, 2021

Episode 13-2021 | In April and July episodes, we explored the OECD two-pillar approach to the challenges of taxation of the digital economy, including a historic July 1 Inclusive Framework (IF) agreement. In this episode, we unpack the most recent IF statement, which fills in details left open in July but leaves unanswered important issues, and to explore remaining political and practical obstacles to implementation. [42:01]

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]