Inside International Tax
Episodes
Whither Wyden - Discussing the Discussion Draft
Contributed by Lukas
Where There's a Will, There's a Ways and Means
Contributed by Lukas
Between Two Pillars, Part Deux: Consensus or Contentious?
Contributed by Lukas
Red Light, Green Book: The Anti-Inversion Proposals
Contributed by Lukas
Green Green Grass of Home: The Outbound Perspective of the Green Book
Contributed by Lukas
If I(RS) Could Turn Back Time: Notice 2023-55 Offers FTC Creditability Rules Relief
Contributed by Lukas
What is the scope of the temporary relief being offered to taxpayers by Notice 2023-55 and what lies ahead for the final foreign tax credit regulation...
Moore than Words: Supreme Court Grants Cert on Section 965 Challenge
Contributed by Lukas
What are the potential ramifications from the Supreme Court's decision to hear the section 965 challenge in Moore? What should taxpayers consider doin...
Ready, Set, GloBE!
Contributed by Lukas
How should companies prepare today for the imminent implementation of Pillar Two tomorrow?
From the OB3 to the OECD: What Does the G7 Agreement Mean for Pillar Two?
Contributed by Lukas
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 sol...
Reconcilable Differences: On the International Tax Provisions in the OB3
Contributed by Lukas
What are the key international tax provisions included in the One Big Beautiful Bill Act, and how could these provisions alter the U.S. international ...
Revenge of the Smith: On the Retaliatory Measures in the OB3
Contributed by Lukas
What are the key implications of the 'revenge tax' of section 899 in the 'One Big Beautiful Bill,' and which taxpayers should be concerned?In this epi...
I'm Just a (Reconciliation) Bill: How the Election Could Shape U.S. and Global Tax Policy
Contributed by Lukas
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 i...
Chevron Unleaded: The Supreme Court Takes the Wheel
Contributed by Lukas
In this episode, we dive into the Supreme Court's recent decision in Loper Bright Enterprises v. Raimondo to overturn Chevron v. Natural Resources Def...
A Tale of Two Pillars, Part II: A Discussion with Michael Plowgian on the Current State of Pillar Two
Contributed by Lukas
In this episode, we are joined by Michael Plowgian, formerly the Deputy Assistant Secretary for International Tax Affairs at Treasury, to discuss the ...
A Tale of Two Pillars, Part I: A Discussion with Michael Plowgian on the Current State of Pillar One
Contributed by Lukas
In this episode, we are joined by Michael Plowgian, formerly the Deputy Assistant Secretary for International Tax Affairs at Treasury, to explore the ...
Greener on the Other Side? The Inbound Perspective of the Green BookState of Play: State Taxation of Foreign Income After the TCJA
Contributed by Lukas
Sovereign Immunity: How Recent Regs Redraw the Lines for the Section 892 Exemption
Contributed by Lukas
In this episode, we explore the evolving landscape for sovereign wealth and foreign government pension funds under section 892, highlighting the lates...
Duty Unbound: Learning Resources and the Future of Tariffs
09 Apr 2026
Contributed by Lukas
In this episode, we unpack the Supreme Court's recent decision holding that the International Emergency Economic Powers Act (IEEPA) does not authorize...
From Dublin to Delaware: Exploring the Factors Driving the Inbound Question
05 Mar 2026
Contributed by Lukas
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 forei...
Pillar Two Side-by-Side: Has the OECD Finally Found Its Stride?
13 Jan 2026
Contributed by Lukas
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-Si...
The Interplay of OB3, BEAT, and CAMT: A Virtuous Cycle or Circular Firing Squad?
06 Nov 2025
Contributed by Lukas
In this episode of Inside International Tax, we examine how recent OB3 legislative changes - including changes to domestic R&E expenses, the reinstate...
A Conversation with Retiring Tax Principal Tom Zollo
30 Sep 2025
Contributed by Lukas
In this episode, Tom Zollo, Principal in the KPMG Washington National Tax - International Tax practice, shares insights from decades in transfer prici...
MAP Quest: A Conversation with Doug O'Donnell on Cross-Border Dispute Resolution
03 Sep 2025
Contributed by Lukas
Doug O'Donnell joins the podcast to explore how the Mutual Agreement Procedure (MAP), a treaty-based process for resolving double taxation disputes be...
The Art of the Global Tax Deal: The US Negotiates with the OECD on Pillar Two
08 May 2025
Contributed by Lukas
What concessions are the United States seeking from the OECD's Inclusive Framework on the Pillar Two regime and how might they protect U.S. multinatio...
Clear Skies Ahead or Storm on the Horizon? Navigating the New Digital Content and Cloud Regulations
03 Apr 2025
Contributed by Lukas
What should taxpayers know about the digital content and cloud regulations, and how should they prepare for their impact?In this milestone 50th episod...
Duty Bound: How Tariffs Could Reshape the Tax Landscape
07 Mar 2025
Contributed by Lukas
In this episode of Inside International Tax, we delve into the tariffs recently announced by the Trump administration, exploring the president's autho...
From Taxed to Tracked - Navigating the Complexities of the Proposed PTEP Regulations
05 Feb 2025
Contributed by Lukas
In this episode, we explore the key concepts of the recently proposed previously taxed earnings and profits, PTEP, regulations and their practical imp...
Let's Get Digital - Value Chain Planning Opportunities Amidst Digital Transformation
08 Jan 2025
Contributed by Lukas
In this episode, we explore the basics of digital transformation and value chain management, focusing on how digital intangibles and digital technolog...
A Dual-Edged Sword: Exploring the Proposed DCL Regulations
05 Nov 2024
Contributed by Lukas
In this episode, we explore the most critical aspects of the proposed dual consolidated loss, DCL, regulations, including how a DCL used in computing ...
CAMT-astic or CAMT-astrophe? Making Sense of the International Tax Provisions in the Proposed CAMT Regulations
15 Oct 2024
Contributed by Lukas
In this episode, we discuss the international tax provisions in the recently released proposed CAMT regulations, including how the proposed regulation...
All About that Baseline: Preparing for a Future with Amount B
03 Sep 2024
Contributed by Lukas
With the implementation of Amount B potentially around the corner, in this episode we explore Amount B, its impact on taxpayers, the cadence and conto...
Funding the Flames: Why Foreign Multinationals Must Take Stock of the Stock Buyback Excise Tax
02 May 2024
Contributed by Lukas
In this episode, we explore how the recently issued proposed regulations addressing the stock buyback excise tax can impact foreign multinationals, ho...
Put Your Best FEEP Forward: Preparing for the New Section 987 Regulations
07 Mar 2024
Contributed by Lukas
In this episode, we explore the newest set of proposed section 987 regulations, including how they have evolved in the decades since the first proposa...
Notice 2023-80: FTCs, DCLs, and the GloBE Rules, Oh My!
08 Feb 2024
Contributed by Lukas
What guidance does Notice 2023-80 provide regarding the interaction of the GloBE rules with both foreign tax credits and dual consolidated losses and ...
More on Moore: Unpacking the Recent Oral Arguments in the Moore Case
19 Dec 2023
Contributed by Lukas
What can be gleaned from the oral arguments before the Supreme Court in Moore v. United States on the constitutionality of the mandatory repatriation ...
Cross-Border CAMT: Unpacking the International Aspects of the New IRS Notice
15 Nov 2023
Contributed by Lukas
Exploring the international tax aspects of Notice 2023-64, which provides interim guidance on CAMT.
Pillar Two Reloaded: The OECD Releases a Second Round of Administrative Guidance
12 Oct 2023
Contributed by Lukas
What guidance was released in the second round of OECD Pillar Two administrative guidance and where do we stand on the worldwide implementation of the...
Homeward Bound: The Intangible Journey
25 May 2023
Contributed by Lukas
What relief do the proposed section 367(d) regulations offer, and where do the rules fall short?
Around the GloBE: Tracking the Pillar Two Rules' Progress
19 Apr 2023
Contributed by Lukas
Update on the worldwide implementation of GloBE rules and recent OECD administrative guidance
I Literally CAMT: Dealing with Your International Min Tax Issues
29 Mar 2023
Contributed by Lukas
What are the most pressing CAMT international tax issues for which taxpayers need guidance today?
Exploring the Impact of Notice 2023-7 on Transactions
01 Mar 2023
Contributed by Lukas
What to Expect when You're Expecting Pillar Two
01 Feb 2023
Contributed by Lukas
Credit Repair: Do the Proposed Foreign Tax Credit Regulations Do Enough?
16 Dec 2022
Contributed by Lukas
A Done Deal: How M&A Today Can Impact Your GloBE Liability Tomorrow
05 Oct 2022
Contributed by Lukas
CAMT Stop, Won't Stop: Corporate AMT under the Inflation Reduction Act
16 Aug 2022
Contributed by Lukas
Ripple FX: The U.S. Tax Impact of a Strong U.S. Dollar
03 Aug 2022
Contributed by Lukas
A Tough Pillar to Swallow: Computing GloBE ETR for U.S. Multinationals
22 Jun 2022
Contributed by Lukas
Planet of the APA: Liberty Global and the Future of Reg Invalidity
12 May 2022
Contributed by Lukas
No Credit Where Credit Is Due: Exploring the Practical Impact of the Foreign Tax Credit Regulations
06 Apr 2022
Contributed by Lukas
The GloBE Rules: Bye Bye American Pie
15 Mar 2022
Contributed by Lukas
Capitalization Punishment: The New Rules of Section 174
18 Feb 2022
Contributed by Lukas
The Credit Crunch: Exploring the Impact of the Final Foreign Tax Credit Regulations
01 Feb 2022
Contributed by Lukas
Around the GloBE: Exploring the Pillar Two Model Rules
11 Jan 2022
Contributed by Lukas
Back to the Build Back Better Act: Doing the Bare Minimum
11 Nov 2021
Contributed by Lukas
Between Two Pillars, Part 3: Mind the Gap
21 Oct 2021
Contributed by Lukas
ESG, OMG - The Intersection of Tax and the ESG Movement
13 Aug 2021
Contributed by Lukas
State of Play: State Taxation of Foreign Income After the TCJA
24 May 2021
Contributed by Lukas
Between Two Pillars: The U.S. at the OECD
29 Apr 2021
Contributed by Lukas
Tax Reform Rewind: The White House and The White Paper
15 Apr 2021
Contributed by Lukas
SPAC, Eggs, SPAC, SPAC, Bacon, and SPAC
09 Apr 2021
Contributed by Lukas
IP, Where Art Thou?
22 Mar 2021
Contributed by Lukas