Ernst & Young Podcast Directory

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• International Tax Podcast Channel

  International Tax Podcast
  

  Current Episodes: International Tax Outlook

  • International Tax Outlook – February 2007
    Jose Murillo, a senior member of Ernst & Young's International Tax Services Group in Washington, D.C., takes a look at recently issued IRS temporary and proposed regulations under section 367(a) on the filling of gain recognition agreements and the impact of subsequent transactions on previously filed GRAs. (Approx. 10 min.)

  • David Joranko, a senior partner in Ernst & Young's International Tax Services Group in Cleveland, addresses recent IRS Chief Counsel Advice on the effective dates for claiming benefits under the foreign sales corporation (FSC) and extraterritorial income (ETI) rules on long-term sales and lease transactions. This is of particular interest to U.S. exporters with long-term sales and contracts, such as those in the defense industry, and those with long-term leases or licenses, such as those in the film, software, and financial services industries. (Approx. 10 min.)

  • International Tax Outlook – January 2007
    Margie Rollinson, Director of Ernst & Young's International Tax Services Group in Washington, D.C., reviews recent IRS Notice 2007-9, which provides guidance on the application of the CFC-to-CFC look-through rule of Section 954(c)(6). (Approx. 10 min.)

  • Peg O'Connor, a senior member of Ernst & Young's International Tax Services Group in Washington, D.C., takes a look at IRS Notice 2007-13, which announced some important changes to the substantial assistance rules of Subpart F. (Approx. 10 min.)

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  Current Episodes: Global and Washington Dispatch

  US multinationals and non-US multinationals with US operations will find our monthly Washington Dispatch helpful in staying on top of US international tax developments. And our Global Dispatch, available every other month, will help multinational corporations stay on top of critical international tax news.

  1. International Tax – Washington Dispatch – April 2007
     IRS Proposed Regulations Issued to Combat Transactions Aimed at Generating Foreign Tax Credits – Final Dual Consolidated Loss Regulations Published -- Important Opportunity for U.S. Companies Contributing to Foreign Defined Benefit Plans – IRS Issues Directive on Section 482 Cost Sharing "Buy-in Payments" – IRS Addresses Commensurate With Income Standard under Section 482 – PLR 200712007 Concludes Ownership Through Disregarded Entity Qualifies as Direct Ownership for Dividend Withholding Exemption in U.S.-U.K. Tax Treaty – United States, Brazil Sign Tax Information Exchange Agreement – IRS Rules ICE Futures Is a Qualified Board or Exchange for Section 1256 Purposes – E&Y's International Tax Online Reference Service Provides Updates on Significant Income Tax Changes in 25 Countries (Approx. 15 min.)

  2. International Tax – Global Dispatch – February/March 2007
     UK's Marks & Spencer Decision Upheld on Appeal – Austrian Decree Restricts Tax Losses of Absorbed Foreign Subs – Austrian Tax Administration Extends Dividend W/Holding Exemption for EU Partnership Holding Austrian Shares – Germany's 2008 Tax Reform Update – Dutch Group Interest Box Partially Approved by European Commission, Dutch Patent Box Regime Retroactive to January 1, 2007 – New Portuguese Local Finance Law Reduces CIT – Switzerland, EU Sparring Over Swiss Cantonal Tax Regimes – India's Union Budget 2007 Released – India Considering Limited Liability Partnerships – Indonesia Introduces New Tax Incentives for Specified Industries – Singapore Budget Reduces CIT, Introduces Financial Industry Incentives – Thai Cabinet Approves Changes to Foreign Business Act – Brazil Provides CIDE Exemption for Cross-Border Software License Payments – U.S., Bulgaria Sign First-Ever Tax Treaty – Uruguay Approves Tax Reform Effective July 1, 2007 (Approx. 28 min.)

  3. International Tax – Washington Dispatch – March 2007
     Guardian Industries Foreign Tax Credit Case Affirmed on Appeal – U.S., Bulgaria Sign First-ever Income Tax Treaty – IRS Rev. Proc. 2007-23 Guidance on Tax Treatment of IP Cross-Licensing Arrangements – IRS Guidance on FSC / ETI Product Grouping Elections – 8th Annual APA Report Profiled – Ernst & Young's International Tax Online Reference Service Now Available (Approx. 15 min.)

  4. International Tax – Washington Dispatch – February 2007
     Bush Administration's FY '08 Budget – IRS Regulations under Section 367(a) re: GRAs – IRS Chief Counsel Advice: FSC/ETI Application to Long-term Sale / Lease Transactions – IRS Addresses Section 936 Exit Strategies – IRS Rev. Proc 2007-21 on Penalty Rescission – Ernst & Young's New International Tax Online Reference Service Debuts (Approx. 15 min.)

  5. International Tax – Washington Dispatch – January 2007
     IRS Notice 2007-9: First Guidance on Application of CFC-to-CFC Look-Through Rule — IRS Notice 2007-13 Announces Significant Change to Subpart F Substantial Assistance Rule — IRS Final Regs Issued on Space, Ocean, Communications Sourcing — IRS to Add Bulgarian Entity to CTB Per Se List — Guidance on New Transfer Pricing Intercomany Services Regs — IRS Prefiling Agreement Program Extended — Schedule M-3 Now Required for Many Partnerships — U.S.-France Income Tax, Estate Tax Protocols Enter into Force (Approx. 15 min.)

  6. International Tax – Global Dispatch – December 2006/January 2007
     UK Issues Pre-Budget Report; Addresses Cadbury Schweppes — ECJ Rules on UK Dual Exemption / Credit System — Belgium Abolishes Dividend Withholding Tax — Israel Finalizes Transfer Pricing Regulations — OECD Issues Discussion Draft on Treatment of Services — Spain Approves Tax Reform — Australia Enacts Important Capital Gains Tax Legislation — China's Pending Unified Corporate Tax Reform Moving Toward Final Approval — Singapore-Germany Tax Treaty Ratified — Mexico Issues Wide-Ranging Draft Tax Reform Package — Mexico Issues New Maquiladora Rules — U.S.-France Income Tax, Estate Tax Protocols in Force — New Venezuela Decree on Technology Transfer, Technical Assistance, and IP (Approx. 23 min.)

  7. International Tax – Washington Dispatch – December 2006
     U.S., Belgium Sign New Bilateral Income Tax Treaty – Congress Passes "Tax Relief and Health Care Act of 2006" Including Tax Measures and Technical Corrections – Research Credit Retroactivly Extended – Narrow Amendment to Section 199 Production Deduction For Puerto Rico – Technical Corrections Impact CFC Look-Through Rule – IRS Addresses CFC Income for Regulated Investment Companies (Approx. 11 min.)

  8. International Tax – Global Dispatch – October/November 2006
     Canada Announces Tax Fairness Plan; Includes New Distribution Tax – New Canada-Mexico Treaty May Adversely Affect Canadian Investors – Belgium to Abolish Domestic Dividend Withholding for Corporate Investors – ECJ Rules in Cadbury Schweppes UK CFC Case – German Authorities Issue Final Memorandum on Related Party Share Sales Financed with "Tainted Debt" – German Tax Committee Agrees to 2008 Business Tax Reform Cornerstones – Spain-Switzerland Amending Protocol Published in Official Gazette – China-Mauritius Sign Important Tax Protocol – Malaysia 2007 Budget Released – Chile Introduces Draft Legislation to Reduce Royalty Withholding – Mexico Merges Maquiladora, PITEX Programs – U.S., Belgium Initial New Tax Treaty – U.S., Iceland Initial New Tax Treaty – U.S., UK Reach Dual Consolidated Loss Agreement (Approx. 26 min.)

  9. International Tax – Washington Dispatch – November 2006
     New U.S. Model Income Tax Treaty and Technical Explanation Released – IRS Issues Proposed Regs Under Section 362(e)(2) on Built-in Loss Limitation – IRS Notice 2006-99: Plans to Eliminate Interest for "Cured" Section 1441 Withholding Failures – IRS Notice 2006-101: List of U.S. Tax Treaties for Qualifying for Reduced Dividend Withholding Under Section 1(h)(11) –- IRS Legal Memo Addresses Cross-Border Secured Financing Transactions (Approx. 16 min.)

  10. International Tax – Washington Dispatch – October 2006
      U.S. Legislative Developments – Tax Technical Corrections Act of 2006 – International Tax Simplification Act of 2006 – Joint Committee on Taxation Report on "Tax Gap" – U.S., Belgium Initial Income Tax Treaty – U.S., Iceland Initial Tax Treaty – U.S.-UK Agreement on Dual Consolidated Losses – IRS Notice 2006-85 Shutting Down "Killer B" Transactions – Final Section 752 Regs on Disregarded Entities – IRS Proposed Regs on RIC Foreign Source Reporting – IRS Legal Memo on Cross-Border Financial Instruments (Approx. 16 min.)

  11. International Tax – Washington Dispatch – September 2006
      US Currency Regs Released – IRS Issues PTI Regs – PLR on Interposed UK Disregarded Entity – Interest Expense Deductions for Foreign Banks in US – Glaxo SmithKline in Record Billion Dollar Transfer Pricing Settlement – IRS Appeals Xilinx – US, Germany Diplomatic Notes Amend New Tax Protocol – US Legislative Update (Approx. 16 min.)

  12. International Tax – Global Dispatch – August/September 2006
      Important German Draft Legislation – EU Transfer Pricing Code of Conduct – Details on Dutch Tax Bill – Italian Beneficial Ownership Ruling – Luxembourge 1929 Holding Company Regime Illegal – Spain Approves Tax Reform – Australian Tax Office Guidance on Managing Tax Risk – China, Hong Kong Sign Tax Agreement – Korea's New Tax Haven Black List – Argentina, Switzerland Sign New Tax Protocol – US Releases Transfer Pricing Services Regs – US-Sweden Protocol, US-Bangladesh Treaty in Force (Approx. 24 min.)

  13. International Tax – Washington Dispatch – July/August 2006
      IRS Issues Long-Awaited Section 482 Services and Intangibles Regulations – Proposed Regs Under Sections 901 and 902 Released – Important, Final Section 367(b) Regulations Issued – IRS Notice 2006-70 for Applying Temporary Inversion Regs – Federal Circuit in Coltec Hands Big Win to Government in Economic Substance Case – U.S.-Sweden Tax Protocol in Force August 31, 2006 – New U.S.-Bangladesh Treaty In Force – Coming U.S. Treaty Hearing in Doubt – Accounting for Uncertainty in Income Taxes (FIN 48); Critical for all MNCs (Approx. 27 min.)

  14. International Tax – Global Dispatch – June/July 2006
      Dutch Government Submits Proposals to Strengthen Investment Climate – ECJ Rules on Belgium Coordination Centers – New Belgium-Macau Tax Agreement – Italian Permanent Establishments Interest Deduction Limit – Dutch Treaty Update – Russian Profits Tax Exemption – Russian Deduction for Land Costs – Israeli Transfer Pricing Regs – New Turkish Tax Code – Australian Capital Gains Taxation Changes – Japanese Transfer Pricing Revisions – U.S.-Germany Protocol Signed – U.S.-Finland Protocol Signed – New Venezuela-Austria Tax Treaty (Approx. 26 min.)

  15. International Tax – Washington Dispatch – June 2006
      IRS Issues Proposed Regs Under Sections 367, 1248 – IRS Temp and Prop Regs Target Cross-Border Inversion Transactions – IRS Notice 2006-46 Announces Coming Final Regs on Transfer of US Real Property Interests – PLR 200620017: Finco May Satisfy Active Trade or Business Test Via Activities of Connected Persons – Coming IRS Rev Proc Will Allow Taxpayers to Change Methods of Interest, R&E Apportionment Without Prior Consent – US Signs Tax Protocols with Finland, Germany (Approx. 14 min.)

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• Pharmaceuticals Podcast Channel

  Pharmaceuticals Podcast
  Today’s pharma companies face an ever-shifting industry landscape full of challenges and opportunities. What choices can they make to establish a new equilibrium that balances risks and rewards? To avoid major pitfalls? And to grow their businesses globally? Hear Global Pharmaceutical Center leaders address these questions in the current episode of the podcast series:

  • "Capturing the Global Advantage"
  • "Cross-Border Value Chains"
  • "Stakeholder Confidence"
  • "Emerging Growth Markets"

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• State and Local Tax Podcast Channel

  State and Local Tax Podcast
  Ernst & Young's most recent podcast series, State and Local Tax Outlook, is designed to provide U.S. companies and tax professionals with a brief overview of significant issues in state and local taxation. As pressing matters arise, Ernst & Young's State and Local Tax practice will produce such podcasts to help companies keep abreast of select legislative matters and address critical tax issues that may influence their operations.

  Current Episode: State and Local Tax Outlook

  • State and Local Tax Outlook – April 2007
    In this inaugural State and Local Tax Outlook podcast, Ernst & Young addresses pressing issues that may influence U.S. companies. In this issue, items include state tax developments at the U.S. Supreme Court, a discussion about a recent taxpayer-favorable sales and use tax nexus decision from Louisiana, and a brief overview of state trends toward combined reporting. (Approx. 10 min.)

     Subscribe to State and Local Tax Podcast (Requires registration)

• Transactions Podcast Channel

  Transactions Podcast Channel
  No matter what the size of your company, where it is located or the business you are in, transactions can help your company grow, prosper or reinvent itself. In this podcast, professionals in all aspects of the deal lifecycle discuss how to evaluate, structure and execute the deals that can enhance your organization.

  Current Episodes

  When companies think about investing in emerging markets, Russia is often overlooked in favor of China and India. Yet this is an economy of 145 million people, growing GDP and consumer spending, tremendous infrastructure needs and a strategic location between Europe and Asia.

  Ernst & Young Transaction Advisory Services has created a Podcast series, Doing Transactions In…, a series that explores deal-making in emerging markets. Hosted by Philip Bass, this 5-part session explores various aspects of doing transactions in Russia. Paul Murphy, a Transaction Leader at Ernst & Young CIS (BV), Russia, is the featured guest.

  Doing Transactions in Russia: Understanding the Market
  When companies think about opportunities in emerging markets, Russia is often at the top of the list. What should investors know about this country to be successful there? Listen and learn about changes that have made Russia an attractive market to foreign investors.

  Doing Transactions in Russia: Who Are the Players?
  Who are the investors in Russia? What companies are seen as the big players in this emerging giant? Listen and learn about who the foreign investors are, who they will be in the future, and what is the likely competitive picture in the future.

  Doing Transactions in Russia: Identifying Targets
  The Russian economy is growing by leaps and bounds, and with it, the transaction market is expanding rapidly. Cross-border investors can find tremendous opportunities there. Listen and learn how foreign investors target investment opportunities in Russia.

  Doing Transactions in Russia: Executing Transactions in Russia
  When investing in Russia, legal, regulatory, and tax issues are particularly significant. To overcome potential risks, having the right deal team and doing thorough due diligence is key. Listen and learn what companies should know when executing deals in Russia.

  Doing Transactions in Russia: Investment Success Factors
  Like any transaction, integration is a key factor when doing deals in Russia. Striking the perfect balance of global best practices with local structure and execution determine deal outcomes. Listen and learn to the factors determining cross-border deal success in Russia.

   Subscribe to Transactions Podcast Channel (Requires registration)