Episodes

  • Let's Get Digital - Value Chain Planning Opportunities Amidst Digital Transformation

    Let's Get Digital - Value Chain Planning Opportunities Amidst Digital Transformation
    Jan 8 2025
    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.
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    23 mins
  • I'm Just a (Reconciliation) Bill: How the Election Could Shape U.S. and Global Tax Policy

    I'm Just a (Reconciliation) Bill: How the Election Could Shape U.S. and Global Tax Policy
    Dec 4 2024
    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 Winnick, from the KPMG Washington National Tax, WNT, International Tax group, to answer these questions and more on the latest episode of Inside International Tax.
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    34 mins
  • A Dual-Edged Sword: Exploring the Proposed DCL Regulations

    A Dual-Edged Sword: Exploring the Proposed DCL Regulations
    Nov 5 2024
    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 Holland from the KPMG Washington National Tax International Tax group, to answer these questions and more on the latest episode of Inside International Tax.
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    29 mins
  • CAMT-astic or CAMT-astrophe? Making Sense of the International Tax Provisions in the Proposed CAMT Regulations

    CAMT-astic or CAMT-astrophe? Making Sense of the International Tax Provisions in the Proposed CAMT Regulations
    Oct 15 2024
    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.
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    28 mins
  • All About that Baseline: Preparing for a Future with Amount B

    All About that Baseline: Preparing for a Future with Amount B
    Sep 3 2024
    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.
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    28 mins
  • Chevron Unleaded: The Supreme Court Takes the Wheel

    Chevron Unleaded: The Supreme Court Takes the Wheel
    Jul 31 2024
    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.
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    32 mins
  • A Tale of Two Pillars, Part II: A Discussion with Michael Plowgian on the Current State of Pillar Two

    A Tale of Two Pillars, Part II: A Discussion with Michael Plowgian on the Current State of Pillar Two
    Jun 26 2024
    In this episode, we are joined by Michael Plowgian, formerly the Deputy Assistant Secretary for International Tax Affairs at Treasury, to discuss the rapid global progress in Pillar Two enactment, the outstanding issues related to implementation, and the future of the Pillar Two initiative more broadly.
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    30 mins
  • A Tale of Two Pillars, Part I: A Discussion with Michael Plowgian on the Current State of Pillar One

    A Tale of Two Pillars, Part I: A Discussion with Michael Plowgian on the Current State of Pillar One
    Jun 7 2024
    In this episode, we are joined by Michael Plowgian, formerly the Deputy Assistant Secretary for International Tax Affairs at Treasury, to explore the fundamental shift in cross-border taxation that Pillar One represents and to update us on the status of Amounts A and B, the hurdles that still exist for implementation, and the United States' current negotiating position with respect to Pillar One
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    25 mins