Inside International Tax

What has Senator Wyden's discussion draft added to the tax reform effort?

What are the international building blocks in the Build Back Better bill?

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. Join us as our co-hosts Gary Scanlon and Kristen Gamboa interview Lou Abad, a Principal in the KPMG Washington National Tax - Trade and Customs practice, to answer these questions and more on the latest episode of Inside International Tax.

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. Join us as our co-hosts Gary Scanlon and Kristen Gamboa interview Gordon Warnke (Principal in charge of the Complex Transactions Group and Co-Principal in charge of the WNT M&A Tax practice and Stephen Massed, a principal in the same group, to answer these questions and more.

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. Join us as our co-hosts Gary Scanlon and Kristen Gamboa interview Dan Winnick (Principal, KPMG Washington National Tax - International Tax), and Kirstin Gallagher (Principal, KPMG International Tax - Financial Services Group and US Tax Leader for Sovereign Wealth and Pension Funds), to answer these questions and more.

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. Join us as our co-hosts Gary Scanlon and Kristen Gamboa interview Michael Plowgian (Co-Principal in Charge, KPMG Washington National Tax - International Tax), along with Conrad Turley (Tax Policy Leader and Chair of the Global Tax Policy Leadership Group - KPMG Global), and Alistair Pepper (Managing Director, KPMG Washington National Tax - Economic and Valuation Services) to answer these questions and more on the latest episode of Inside International Tax.

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. Join us as our co-hosts Gary Scanlon and Kristen Gamboa interview Seevun Dunckzar (Managing Director, KPMG Washington National Tax - International Tax), to review these scenarios and more on the latest episode of Inside International Tax.

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. Join us as our co-hosts Gary Scanlon and Kristen Gamboa interview Tom Zollo to cover these topics and more on the latest episode of Inside International Tax.

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. Join us as our co-hosts Gary Scanlon and Kristen Gamboa interview Doug O'Donnell, formerly IRS Acting Commissioner and previously a participant in the OECD Forum on Tax Administration, to answer these questions and more on the latest episode of Inside International Tax.

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. Join us as our co-hosts Gary Scanlon and Kristen Gamboa interview returning guest Michael Plowgian, a Principal in the KPMG WNT - International Tax practice, and Marcus Heyland, a Principal in the KPMG WNT - Economic and Valuation Services practice, to answer these questions and more on the latest episode of Inside International Tax.