Episodes

  • 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.
    Show More Show Less
    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.
    Show More Show Less
    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.
    Show More Show Less
    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
    Show More Show Less
    25 mins
  • 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.
    Show More Show Less
    26 mins
  • 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.
    Show More Show Less
    26 mins
  • 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?
    Show More Show Less
    27 mins
  • 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?
    Show More Show Less
    25 mins