Episodios

  • 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 m
  • 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 m
  • Funding the Flames: Why Foreign Multinationals Must Take Stock of the Stock Buyback Excise Tax

    Funding the Flames: Why Foreign Multinationals Must Take Stock of the Stock Buyback Excise Tax
    May 2 2024
    In this episode, we explore how the recently issued proposed regulations addressing the stock buyback excise tax can impact foreign multinationals, how they both limit and broaden the scope of the funding rule first introduced by Notice 2023-2, and what foreign multinationals should be doing now to ready themselves for the excise tax.
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    26 m
  • Put Your Best FEEP Forward: Preparing for the New Section 987 Regulations

    Put Your Best FEEP Forward: Preparing for the New Section 987 Regulations
    Mar 7 2024
    In this episode, we explore the newest set of proposed section 987 regulations, including how they have evolved in the decades since the first proposals and what taxpayers should be thinking about now as we await finalization.
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    26 m
  • Notice 2023-80: FTCs, DCLs, and the GloBE Rules, Oh My!

    Notice 2023-80: FTCs, DCLs, and the GloBE Rules, Oh My!
    Feb 8 2024
    What guidance does Notice 2023-80 provide regarding the interaction of the GloBE rules with both foreign tax credits and dual consolidated losses and what questions still remain?
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    27 m
  • More on Moore: Unpacking the Recent Oral Arguments in the Moore Case

    More on Moore: Unpacking the Recent Oral Arguments in the Moore Case
    Dec 19 2023
    What can be gleaned from the oral arguments before the Supreme Court in Moore v. United States on the constitutionality of the mandatory repatriation tax?
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    25 m
  • Cross-Border CAMT: Unpacking the International Aspects of the New IRS Notice

    Cross-Border CAMT: Unpacking the International Aspects of the New IRS Notice
    Nov 15 2023
    Exploring the international tax aspects of Notice 2023-64, which provides interim guidance on CAMT.
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    33 m
  • Pillar Two Reloaded: The OECD Releases a Second Round of Administrative Guidance

    Pillar Two Reloaded: The OECD Releases a Second Round of Administrative Guidance
    Oct 12 2023
    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 GloBE rules?
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    31 m