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Inside International Tax

KPMG LLP (U.S.)
KPMG
International Tax
P-Tep
Section 987
IRS
Stock Buyback Excise Tax
Tax Cuts and Jobs Act
US Tax Regulations
Loper Bright Enterprises V. Raimondo
U.S. Treasury
Inflation Reduction Act
Chevron Deference
Transfer Pricing
Foreign Exchange Exposure Pool
Gain and Loss Computation
U.S. International Tax Compliance
Corporate Tax
Foreign Multinationals
OECD
Tax Law

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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Artwork for Inside International Tax

Latest Episodes

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... more

YouTube

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 shapin... more

YouTube

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 Gl... more

YouTube

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... more

YouTube

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Recent Guests

Gordon Warnke
Principal in charge of the Complex Transactions Group and co-principal in charge of the WNT M&A tax practice
KPMG
Episode: From Dublin to Delaware: Exploring the Factors Driving the Inbound Question
Steve Massed
Principal in the same group as Warnke
KPMG
Episode: From Dublin to Delaware: Exploring the Factors Driving the Inbound Question
Kirstin Gallagher
Principal in KPMG's International Tax, Financial Services Group and US Tax Leader for Sovereign Wealth and Pension Funds
KPMG
Episode: Sovereign Immunity: How Recent Regs Redraw the Lines for the Section 892 Exemption
Conrad Turley
Head of Tax Policy for the Global Tax Policy Group
KPMG
Episode: Pillar Two Side-by-Side: Has the OECD Finally Found Its Stride?
Alistair Pepper
Managing Director in KPMG's WNT EVS Practice
KPMG
Episode: Pillar Two Side-by-Side: Has the OECD Finally Found Its Stride?
Sevan Dunckzar
Managing Director in KPMG's WNT International Tax Practice
KPMG
Episode: The Interplay of OB3, BEAT, and CAMT: A Virtuous Cycle or Circular Firing Squad?
Tom Zollo
Principal in KPMG's Washington National Tax Practice
KPMG
Episode: A Conversation with Retiring Tax Principal Tom Zollo
Doug O'Donnell
Former acting IRS commissioner and current co-leader of KPMG's Tax Controversy and Dispute Resolution Group.
KPMG
Episode: MAP Quest: A Conversation with Doug O'Donnell on Cross-Border Dispute Resolution
Ron Dabrowski
Principal in charge of KPMG's WNT International Tax Practice
KPMG
Episode: Reconcilable Differences: On the International Tax Provisions in the OB3

Hosts

Gary Scanlon
Principal in KPMG's WNT International Tax Practice; hosts various segments on international tax policy.
Kristen Gamboa
Managing Director in KPMG's WNT International Tax Practice; co-hosts discussions on Section 892, Pillar 2, and OB3 topics.

Reviews

5.0 out of 5 stars from 50 ratings
  • awesome

    exceptional make more podcasts

    Apple Podcasts
    5
    JVo12
    Canada2 years ago
  • Informative and timely topics

    Very informative and timely topics. Jokes could be funnier, but still quite good in spite of that.

    Apple Podcasts
    5
    J-Ho (4real)
    United States4 years ago
  • Informative and timely topics

    Very informative and timely topics. Jokes could be funnier, but still quite good in spite of that.

    Apple Podcasts
    5
    J-Ho (4real)
    United States4 years ago
  • Inside International Tax

    Thank you, please keep producing episodes.

    Apple Podcasts
    5
    kmortoncpa
    United States5 years ago

Listeners Say

Key themes from listener reviews, highlighting what works and what could be improved about the show.

Industry-standard depth appreciated; jokes occasionally noted as not very funny.
Overall favorable reception for expert guests and actionable takeaways.
Feedback highlights clear, practical insights with room for lighter moments.
Positive about timely, informative topics and strong host expertise.

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Talking Points

Recent interactions between the hosts and their guests.

From Dublin to Delaware: Exploring the Factors Driving the Inbound Question
Q: Do changes make the U.S. more attractive than other jurisdictions or do they merely level the playing field?
The changes are seen as making the U.S. more attractive than in the past and, relative to other jurisdictions, more about leveling the playing field by reducing tax frictions while still retaining certain minimum tax and reporting complexities.
From Dublin to Delaware: Exploring the Factors Driving the Inbound Question
Q: Steve, what do we mean when we talk about inbounding?
Inbounding refers to placing a U.S. corporation on top of a foreign-parity group or transferring assets while maintaining domicile of the foreign parent, with the goal of benefiting from U.S. tax regime and simplifying operations, while considering form differences that affect tax outcomes.
Sovereign Immunity: How Recent Regs Redraw the Lines for the Section 892 Exemption
Q: What do sponsors and managers of these funds need to know about the regulations?
Investment funds with sovereign wealth investors need to take Section 892 restrictions into account to avoid jeopardizing their exemption status.
Sovereign Immunity: How Recent Regs Redraw the Lines for the Section 892 Exemption
Q: Kirstin, can you tell us what makes the US an attractive destination for sovereign investors?
Sovereign investors tend to be long-term, stable sources of capital, which makes the US very attractive for spreading economic risk and seeking the best investments.
The Interplay of OB3, BEAT, and CAMT: A Virtuous Cycle or Circular Firing Squad?
Q: So, Sevan, how does an increased interest expense deduction for 2025 impact a taxpayer's BEAT liability?
Increasing the amount that is deductible could increase the denominator of the base erosion percentage, which can either help or, if a taxpayer is over the threshold, expose them to additional BEAT liability.

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Frequently Asked Questions About Inside International Tax

What is Inside International Tax about and what kind of topics does it cover?

A series centered on U.S. international tax and OECD guidance, with a strong focus on cross-border policy, BEPS, and dispute resolution. Episodes commonly unpack Section 892 implications for sovereign wealth funds, Pillar 2 developments and safe harbors, and OB3-related changes affecting GILTI/FDII, CAMT, and BEAT. Notable guests are senior KPMG tax professionals and policy experts, offering practical insights for multinational enterprises navigating complex tax regimes. The format tends toward clear, practitioner-focused analysis designed for tax teams, finance leads, and corporate counsel evaluating international tax strategies and compliance. A standout is the consistent emphasis on real-world planning implications, regulatory changes, a... more

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Which podcasts are similar to Inside International Tax?

These podcasts share a similar audience with Inside International Tax:

1. Cross-border Tax Talks
2. EY Cross-Border Taxation Alerts
3. Tax News & Views
4. Talking Tax
5. Tax Notes Talk

How many episodes of Inside International Tax are there?

Inside International Tax launched 5 years ago and published 60 episodes to date. You can find more information about this podcast including rankings, audience demographics and engagement in our podcast database.

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What guests have appeared on Inside International Tax?

Recent guests on Inside International Tax include:

1. Gordon Warnke
2. Steve Massed
3. Kirstin Gallagher
4. Conrad Turley
5. Alistair Pepper
6. Sevan Dunckzar
7. Tom Zollo
8. Doug O'Donnell

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