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Inside International Tax

KPMG LLP (U.S.)

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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20 episodes
Avg 29 min
English

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April 9 · 22 min
Duty Unbound: Learning Resources and the Future of Tariffs
In this episode, we unpack the Supreme Court's recent decision holding that the International Emergency Economic Powers Act (IEEPA) does not authorize the president to impose tariffs, discuss how importers might pursue refunds, and consider what that means for Trump's trade policy going forward.
March 5 · 18 min
From Dublin to Delaware: Exploring the Factors Driving the Inbound Question
In this episode of Inside International Tax, we examine recent U.S. and global tax developments that have leveled the playing field for U.S. and foreign multinationals, the non-tax factors that may driving the decision whether to inbound into the U.S., and the potential costs to inbounding.
February 13 · 28 min
Sovereign Immunity: How Recent Regs Redraw the Lines for the Section 892 Exemption
In this episode, we explore the evolving landscape for sovereign wealth and foreign government pension funds under section 892, highlighting the latest regulatory developments, practical implications for asset managers, and how new guidance is shaping investment strategies and compliance for global investors in the U.S. market.
January 13 · 38 min
Pillar Two Side-by-Side: Has the OECD Finally Found Its Stride?
In this episode, we examine the impact on US and foreign multinationals of the OECD's Side-by-Side Package, which includes the long-awaited Side-by-Side Safe Harbor and other guidance and safe harbors intended to reduce the compliance costs of the GloBE system and protect substance-based credits.
Nov 6, 2025 · 30 min
The Interplay of OB3, BEAT, and CAMT: A Virtuous Cycle or Circular Firing Squad?
In this episode of Inside International Tax, we examine how recent OB3 legislative changes - including changes to domestic R&E expenses, the reinstatement of 100 percent bonus depreciation, and modifications to section 163(j) and FDII - interact with BEAT and CAMT, and what these developments mean for taxpayers.
Sep 30, 2025 · 21 min
A Conversation with Retiring Tax Principal Tom Zollo
In this episode, Tom Zollo, Principal in the KPMG Washington National Tax - International Tax practice, shares insights from decades in transfer pricing and international tax structuring, reflects on recent tax changes, and offers advice for navigating today's evolving landscape as he prepares for retirement.
Sep 3, 2025 · 32 min
MAP Quest: A Conversation with Doug O'Donnell on Cross-Border Dispute Resolution
Doug O'Donnell joins the podcast to explore how the Mutual Agreement Procedure (MAP), a treaty-based process for resolving double taxation disputes between countries, operates at the IRS and internationally, the steps taxpayers should undertake to optimize outcomes, the complexities involved in negotiations between tax authorities, the practical challenges and trends affecting the MAP process, and alternatives to MAP for cross-border dispute resolution.
Jul 31, 2025 · 30 min
From the OB3 to the OECD: What Does the G7 Agreement Mean for Pillar Two?
In this episode of Inside International Tax, we discuss what the implications of the 'side-by-side' solution agreed to by the G7 are, and how this solution impacts U.S. parented groups and the viability of Pillar Two.
Jul 16, 2025 · 32 min
Reconcilable Differences: On the International Tax Provisions in the OB3
The One Big Beautiful Bill Act made significant changes to the GILTI, FDII, BEAT and foreign tax credit regimes. In this episode, we explore how these changes may have altered the U.S. international tax landscape.
Jun 5, 2025 · 27 min
Revenge of the Smith: On the Retaliatory Measures in the OB3
In this episode, we explore how proposed section 899 aims to counteract unfair foreign taxes through specific retaliatory measures, its applicability and scope for taxpayers, and its potential future as it progresses to the Senate.
May 8, 2025 · 17 min
The Art of the Global Tax Deal: The US Negotiates with the OECD on Pillar Two
In this episode, we discuss the concessions the United States is seeking from the OECD's Inclusive Framework on the Pillar Two regime to protect U.S. multinationals from over-taxation and the potential international response to these demands.
Apr 3, 2025 · 37 min
Clear Skies Ahead or Storm on the Horizon? Navigating the New Digital Content and Cloud Regulations
In this milestone 50th episode of the podcast, we explore the key changes in the recently issued final regulations addressing the characterization of digital content and cloud transactions, the new proposed cloud sourcing rule, and the impact these rules could have on taxpayers.
Mar 7, 2025 · 32 min
Duty Bound: How Tariffs Could Reshape the Tax Landscape
In this episode of Inside International Tax, we delve into the tariffs recently announced by the Trump administration, exploring the president's authority to impose them, the potential policy objectives behind their use, and the impact they could have on taxpayers and trade partners.
Feb 5, 2025 · 38 min
From Taxed to Tracked - Navigating the Complexities of the Proposed PTEP Regulations
In this episode, we explore the key concepts of the recently proposed previously taxed earnings and profits, PTEP, regulations and their practical impact on taxpayers. Join us as our host Gary Scanlon interviews his co-host Kristen Gamboa, as well as our guests Tim Chan, from the KPMG Washington National Tax - BTS Passthroughs Tax practice, and Gloria LaBerge, from the Washington National Tax - International Tax practice, to explore these issues and more.
Jan 8, 2025 · 23 min
Let's Get Digital - Value Chain Planning Opportunities Amidst Digital Transformation
In this episode, we explore the basics of digital transformation and value chain management, focusing on how digital intangibles and digital technologies are becoming increasingly important to taxpayers in creating value and optimizing tax outcomes. Join us as our co-hosts Kristen Gamboa and Gary Scanlon are joined by Paul Glunt and Matt McNeill, from the KPMG Value Chain Management practice, to discuss this interesting topic on the latest episode of Inside International Tax.
Dec 10, 2024 · 33 min
I'm Just a (Reconciliation) Bill: How the Election Could Shape U.S. and Global Tax Policy
In this episode, we discuss how the results of the November election in the United States may impact tax policy in the near term, including the ways in which the new Congress may be able to pass tax legislation, what roadblocks may exist, and the impact tax disruptors, such as the expiring TCJA provisions and global tax reform, may have in shaping tax policy for 2025 and beyond. Join us as our co-hosts Kristen Gamboa and Gary Scanlon are joined by returning guests, Michael Plowgian and Dan Winn
Nov 5, 2024 · 29 min
A Dual-Edged Sword: Exploring the Proposed DCL Regulations
In this episode, we explore the most critical aspects of the proposed dual consolidated loss, DCL, regulations, including how a DCL used in computing a Pillar Two GloBE liability could be a 'foreign use,' the effect of intercompany transactions in computing a DCL, and the potential tax liability arising from the proposed disregarded payment loss (DPL) regime targeting deduction-no inclusion outcomes. Join us as our co-hosts Kristen Gamboa and Gary Scanlon are joined by returning guest, Doug Ho
Oct 15, 2024 · 28 min
CAMT-astic or CAMT-astrophe? Making Sense of the International Tax Provisions in the Proposed CAMT Regulations
In this episode, we discuss the international tax provisions in the recently released proposed CAMT regulations, including how the proposed regulations expand the reach of the special scoping rule for foreign-parented groups, provide (mostly) taxpayer-favorable rules to address CFC double counting, and import foreign tax credit limitations and section 482 into the CAMT universe.
Sep 3, 2024 · 27 min
All About that Baseline: Preparing for a Future with Amount B
With the implementation of Amount B potentially around the corner, in this episode we explore Amount B, its impact on taxpayers, the cadence and contour of its global roll-out, and any lingering issues with Amount B that countries are still trying to resolve at the OECD.
Jul 31, 2024 · 32 min
Chevron Unleaded: The Supreme Court Takes the Wheel
In this episode, we dive into the Supreme Court's recent decision in Loper Bright Enterprises v. Raimondo to overturn Chevron v. Natural Resources Defense Council, which set out the existing framework for the interpretation of regulations issued by federal agencies, and explore its impact on the tax regulatory landscape.

Showing 1–20 of 20 episodes