Cross-border Tax Talks

Tariff Strike Zone: IEEPA Refunds, Audit Pressure, and Fragmented Trade

Wed, 15 Apr 2026 10:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Chris Desmond, leader of PwC’s US Global Trade Services practice and, as Doug notes, a ‘reformed transfer pricing partner.’ Doug and Chris discuss the current fragmented trade environment, why tariffs may remain a lasting feature rather than a short cycle, rising customs enforcement, the Supreme Court’s IEEPA decision and the operational complexity of securing refunds, and how companies should assess gross-versus-net refund exposure across suppliers and customers. They also cover why the tariff environment is forcing customs, tax, and transfer pricing teams to work more closely together, how first sale operates and why it remains under scrutiny, and practical steps tax leaders should take on coordination, data, and documentation.

Lost in FX Translation: The latest 987 regs

Mon, 30 Mar 2026 14:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Laura Valestin, an International Tax Services Partner in PwC’s Washington National Tax Services practice, where she focuses on financial transactions. In this episode, recorded at PwC’s International Tax Conference in Carlsbad, Laura unpacks the latest Section 987 developments following Notice 2026-17. Doug and Laura discuss what Section 987 is, why it matters for foreign currency gain or loss in branch and disregarded entity structures, the long regulatory history from the 1991 proposed regulations through the 2024 final rules, the new simplified equity-and-basis-pool method, remittance and loss-suspension mechanics, hedging rules, the proposed CFC election, reliance and applicability dates, and practical taxpayer action items, including comment opportunities and modeling decisions for 2025 and beyond.

Tariffs, Tensions, and Tightropes: A global risk tour

Tue, 17 Mar 2026 11:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Anja Manuel, co-founder and principal at Rice, Hadley, Gates, and Manuel LLC, a strategic consulting firm, and a former diplomat, author, and foreign policy advisor. Doug and Anja discuss the geopolitical forces reshaping cross-border business, including the Iran conflict and its implications for oil, shipping, Gulf investment, and AI infrastructure; China’s internal trajectory, tariffs, critical minerals, Taiwan, and supply-chain strategy; the growth outlook for Southeast Asia and India; Europe’s competitiveness challenges and the war in Ukraine; Venezuela’s political and investment risks; the effect of possible US midterm shifts on foreign policy; and whether international institutions, alliances, and the broader global economy still offer reasons for optimism despite a highly unstable backdrop.

Pillar Two SESHion: ‘Simplified’ safe harbour

Mon, 09 Mar 2026 12:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Steve Kohart, a New York City-based international tax partner at PwC and former advisor to the OECD’s Center for Tax Policy and Administration. Doug and Steve discuss the January side-by-side agreement’s implications for US-parented multinationals, why Pillar Two remains relevant through QDMTTs, and how the CBCR transitional safe harbor bridges to the permanent simplified ETR safe harbor. They unpack what ‘simplified’ really means: financial accounting standards, denominator and numerator adjustments, deferred tax ‘bad DTLs,’ and the practical reality of a third set of books. The conversation also covers JV complications, Chapter 6 M&A/reorg rules, transition provisions (9.1.1–9.1.3) and excess negative taxes, new flexibility for return-to-provision adjustments, integrity rules, and what guidance and compliance planning teams should prioritize next.

OB3 Guidance: 4 big beautiful notices

Tue, 24 Feb 2026 11:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Wade Sutton, a PwC principal who leads the International Tax Team in PwC’s Washington National Tax Services Practice and previously served as Deputy International Tax Counsel at the US Department of the Treasury. Doug and Wade discuss late-2025 Treasury and IRS guidance implementing cross-border provisions in the One Big Beautiful Bill Act (OBBBA), focusing on transition and compliance mechanics that surface on 2025 returns. They walk through Notice 2025-72 (CFC year-end conformity and short-period foreign tax allocation), Notice 2025-75 (final-year coordination of the 'hot potato' rule with Section 951A(2)(B) as the regime shifts to pro rata attribution), Notice 2025-77 (a 10% foreign tax credit haircut for taxes tied to certain previously taxed distributions), and Notice 2025-78 (limits on deduction-eligible export income for certain property and IP sales). They close with downstream interactions (especially CAMT and loss/FTC limitations) and how Pillar Two 'side-by-side' dynamics may influence structuring.

In Jeopardy: Sovereign wealth funds and Section 892

Thu, 12 Feb 2026 12:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Nils Cousin, an international tax partner in PwC’s Washington National Tax Services Practice, for his fourth appearance on the show. Doug and Nils discuss Nils’s April 2024 Jeopardy experience before pivoting to the 1916-era Section 892 exemption: how foreign governments, sovereign wealth funds, and public pension funds use it, and how ‘commercial activity’ and ‘controlled commercial entity’ rules can taint the benefit. They unpack the December 2025 regulation package, highlighting what was finalized (including an inadvertent-activity cure period, the qualified partnership exception, and FIRPTA taint relief) and what remains proposed, especially a framework that presumptively treats many debt acquisitions and workouts as commercial activity. The episode closes with the regulation process, effective-date mechanics, and a January 18 Treasury Secretary tweet, leaving us wondering whether market feedback might drive revisions.

Geopolitical reset: Stability and Agility in 2026

Thu, 29 Jan 2026 10:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Craig Stronberg, Senior Director on PwC’s Intelligence Team. Craig leads analysts focused on macroeconomic and geopolitical intelligence; he previously served in the Office of the Director of National Intelligence. Doug and Craig discuss why business and tax leaders should focus on the geopolitical landscape to understand its impact on cross-border business, including tax. Stability is the new bar for many businesses in 2026, requiring greater agility to deal with change. Craig discusses how many businesses are in a 'wait‑and‑see' mode versus decisive movers across industries. He also describes areas of focus, such as the US policy stance for the Americas, Greenland, and tariffs; the Global South’s rising coordination; and governance strains across the G20. While AI data falsification is a significant concern, Craig suggests practical actions for boards such as enabling direct access to the business’ risk team.

The Global Tax Journey: 2025 to 2026

Thu, 15 Jan 2026 15:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Pat Brown, an International Tax Partner in PwC’s Washington National Tax Services practice and Co-leader of the National Tax Office. Pat previously served as GE’s VP of Tax and Director of Tax Policy. Doug and Pat discuss highlights from 2025: the US day-one Pillar Two executive order and the OECD’s late-year side-by-side package; Section 899; the shifting of DSTs into the trade lane; and the expanding role of the UN for global tax policy. On US policy, they also unpack how OBBBA yielded greater stability; CAMT corrections; stock buyback excise tax guidance; and long-awaited Section 987 rules. Looking ahead to 2026, they assess the potential for additional US tax legislation under reconciliation, as well as the future of Pillar Two, its complexity, and how QDMTTs are now the backbone of Pillar Two.

Pillar Two: The Side-by-Side Package

Fri, 09 Jan 2026 11:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Beth Bell, a Principal in PwC’s Washington National Tax Services Policy Office. She previously served as a Senior Advisor to the US Treasury Department, Tax Counsel for the US House Committee on Ways and Means, and Policy Director and Tax Counsel in the United States Senate. Doug and Beth discuss the OECD’s January 2026 side‑by‑side package: why consensus formed, how the side‑by‑side and UPE safe harbors operate, and why QDMTTs are taking center stage. They cover the simplified ETR safe harbor, the one‑year extension of the transitional CbCR safe harbor, elections and 2024–2025 compliance, enacted‑law accounting effects, the key footnote on UTPR allocation, and the new qualified tax incentives safe harbor, including both expenditure-based and production‑based credits, plus implications for inbound investment and the 2029 stocktake.

Pillar Two: Middle East Roundup

Mon, 22 Dec 2025 13:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Hanan Abboud, a Dubai‑based International Tax and M&A partner who leads PwC’s Pillar Two efforts across the Middle East. Doug and Hanan discuss the Cooperation Council for the Arab States of the Gulf (GCC) region’s corporate tax landscape, including country differences, Zakat as a covered tax, and the prevalence of withholding and treaty networks. They then map Middle East Pillar Two adoption: Bahrain’s QDMTT, Kuwait’s QDMTT, Oman’s IIR, Qatar’s DMTT plus IIR, the UAE’s QDMTT, and Saudi Arabia’s lack of announcements. They dive into filing timelines, estimated payments, the evolving incentive landscape, the intersection with free zones, as well as practical pain points: data, provisioning, governance, and allocating top‑up taxes.

The Pillar Two Origin Story (Part 3) | Beth Bell

Thu, 18 Dec 2025 10:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Beth Bell, a principal in PwC’s Washington National Tax Services Policy group. Beth previously served as a senior advisor at the U.S. Treasury Department, tax counsel for the House Ways and Means Committee, and policy director and tax counsel in the U.S. Senate. Doug and Beth discuss contrasts between Senate personal offices and House committee roles; Ways and Means’ tax jurisdiction; and Beth’s experience moving from Congress to Treasury. Next, they jump into how DST disputes led to Pillar One and ultimately the emergence of Pillar Two; Build Back Better legislation; the Pillar Two model rules; U.S. credit design under Pillar Two; and the new administration’s response to Pillar Two.

After-Tax KPIs: A SVP of Tax’s perspective

Wed, 10 Dec 2025 21:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by returning guest Tadd Fowler, Senior Vice President, Treasurer, and Global Taxes at the Procter & Gamble company. Doug and Tadd discuss US tax policy after the Tax Cuts and Jobs Act, the OB3 package’s priorities and fixes (including interest expense apportionment, GILTI and FDII changes, and maintaining competitiveness), and why certainty still depends on ongoing policymaker education. They examine the OECD Pillar Two ‘side‑by‑side’ concept, the daunting Pillar Two compliance overlay on US rules, and P&G’s own Pillar Two posture. They also cover operating‑model design, incentives and foreign direct investment, how AI augments rather than replaces decisions, and the tax team’s priorities—business partnership, compliance productivity, people and capabilities, and advancing tax certainty through transparency and cooperative programs.

Pillar Two: UK realities

Wed, 03 Dec 2025 15:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Matt Ryan, PwC UK’s International Tax and Treasury Network Leader and the UK’s Pillar Two lead. Recording in Barcelona at PwC’s Global Tax Symposium, they take stock of Pillar Two implementation and the much‑watched ‘side‑by‑side’ agreement. Doug and Matt discuss policymakers’ evolving openness to net CFC tested income (NCTI) coexistence, the UK’s 2027 legislative path with potential effect from 2026, the UTPR safe harbor expiration, practical frictions around POPE reporting, M&A data gaps, and the lack of a global dispute mechanism. They also examine transitional versus permanent safe harbors, potential consequences if Section 899 re‑emerges—including expanded BEAT exposure—and quick UK updates on the 25% corporate rate and the digital services tax.

OB3 Curveballs: Federal Tax interplay and State Tax conformity

Tue, 25 Nov 2025 12:00:00 -0500

Wade Sutton (PwC’s WNTS International Tax Services Leader) guest hosts the podcast and is joined by Rob Ozmun, a State and Local Tax Partner, and Monic Kechik, PwC’s WNTS Federal Tax Services Leader. Together they discuss the OB3 ‘curveballs’ to the federal changes: Section 163(j) - ATI addbacks of depreciation and amortization; Section 174A - domestic expensing; Section 168(k) - the return to 100% bonus depreciation; and Section 168(n) - qualified production property (QPP). They explore how accelerated deductions can trigger BEAT and CAMT via ordering‑rule dynamics and book‑tax timing, creating cash‑vs‑ETR trade‑offs that can be addressed with capitalization provisions. They also examine state conformity models, rapid decoupling (e.g., D.C.), and wrinkles such as California’s departures and R&D credits.

Beyond Pillar Two: Global tax policy update

Wed, 19 Nov 2025 10:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Will Morris, PwC’s Global Tax Policy Leader, from PwC’s Global Transfer Pricing, Customs, and Indirect Tax Conference in Prague. Doug and Will discuss how trade policy now shapes tax outcomes, the G7 ‘side‑by‑side’ debate for Pillar Two, and why geopolitics complicates an Inclusive Framework deal. They explore the EU’s ‘simplification’ agenda (FTT/DEBRA/Unshell pullbacks), overlapping anti‑abuse regimes post-Pillar Two, and whether real simplification is politically feasible. The conversation turns to Digital Services Taxes amid Pillar One uncertainty, potential US responses (including Section 301 and talk of Section 899), and the rise of Significant Economic Presence rules. They close with the UN’s emerging convention, source‑based taxation of services, and the limits of AI and automation when dealing with unstructured taxpayer data.

Tariff Tug-of-War: Coordinating your trade strategy

Thu, 06 Nov 2025 06:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Chris Desmond, a Principal in PwC’s Customs & Trade Practice. Chris leads PwC US’s Global Trade Services. Doug and Chris, while at PwC’s Global Transfer Pricing, Customs, and Indirect Tax Conference in Prague, discuss the Supreme Court’s expedited review of IEEPA‑based tariffs, possible outcomes, and the implications of an estimated ~$108B refund exposure across multiple industries (See our PwC Insight: IEEPA Tarrif: Understanding the Potential outcomes ahead of the Supreme Court’s Ruling for more details). They cover how persistent tariffs elevate customs to the C‑suite and require close integration with transfer pricing and Pillar Two modeling. They also discuss practical mitigations including first sale for export, duty drawback, Harmonized Tariff Schedule (HTS) reclassification and origin analysis, transfer‑pricing alignment, and use of foreign‑trade zones -- paired with rigorous controls as US government scrutiny intensifies. The episode closes with sector‑specific developments and a data‑driven playbook.

Pillar Two in Belgium: QDMTT filing now!

Wed, 29 Oct 2025 11:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Pieter Dere, a partner in PwC Belgium’s International Tax Services practice who leads Belgium’s Pillar Two initiative and co‑hosts the Tax Bites Podcast. Doug and Pieter recorded in Prague at PwC’s Global Transfer Pricing, Customs, and Indirect Tax Conference. They discuss Belgium’s Pillar Two compliance landscape: 2024 applicability of QDMTT/IIR/UTPR, a late‑November 2025 filing cycle; the new e‑platform and XML‑only submissions; transitional safe harbors and JV scope; the ‘general representative’ and joint and several liability; DAC 9 and the OECD MCAA; uncertainty around a G7 side‑by‑side and implications for US‑parented groups; estimated payments; Belgian litigation targeting UTPR; and practical steps to be ready now.

Australia Tax Update: Developments down under

Wed, 15 Oct 2025 13:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Sarah Hickey, a PwC Australia International Tax Partner and the Australian tax desk leader in New York City. Doug and Sarah discuss Australia’s corporate tax landscape (30% headline rate; new thin-cap at 30% of tax EBITDA with a retrospective integrity rule on related‑party debt), investment incentives, the two‑speed CFC regime and “use it or lose it” foreign tax credits, and dividend, interest, and royalty withholding. They cover the diverted profits tax (40% rate; 12‑month evidence window), Pillar Two timing, public CbCR and short‑form restructure disclosures due by end‑2025, and indirect taxes including non‑resident CGT and stamp duty. Finally, they unpack the High Court’s Pepsi decision—no royalty derivation by the US, a 4–3 win on royalties and DPT—and why contract wording anchors royalty analyses.

Careers in Tax: Tell me a story

Wed, 01 Oct 2025 11:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Mitch Schuckman, who is retiring after 39 years at PwC and has held a range of leadership roles, most recently leading PwC’s Global Tax Pursuits. Mitch is also the author of “I’ll Tell You a Great Story” and is a certified professional coach. Doug and Mitch discuss the evolving nature of tax careers, from early technical work to client pursuits and leadership development. The conversation explores the importance of storytelling, the role of professional coaching, and the attributes of high-performing teams and individuals. Mitch shares insights on building trusted advisor relationships, the necessity of collecting diverse experiences, and the challenges and rewards of fostering strong team culture, especially in a post-pandemic, hybrid workplace. Mitch reflects on his career, the significance of mentorship, and his future plans in executive coaching and leadership development.

Pillar Two: Decoding the G7 statement

Thu, 18 Sep 2025 16:00:00 -0400

Wade Sutton (PwC’s Washington National Tax Services - International Tax Services Leader) is joined by Pat Brown, an ITS Partner and Co-Leader of PwC’s Washington National Tax Services practice. Pat previously served as the US Treasury’s Associate International Tax Counsel and has been a frequent guest on the podcast. Wade and Pat take a deeper dive into the future of Pillar Two, focusing on the G7’s ‘side-by-side' agreement. They highlight the historical positions of previous US administrations, why proposed Section 899 was dropped from OBBBA, US dissatisfaction with the lack of accommodations for the US GILTI regime and R&D tax credits, the OECD process and how countries could implement changes, and the potential for simplification including a potential permanent safe harbor. Finally, they look to the future and what may happen next.

One Big Beautiful Podcast, Part 5: Outbound Edition

Thu, 04 Sep 2025 13:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Wade Sutton, a principal who leads the international tax team in PwC’s Washington National Tax Services practice. Doug and Wade discuss OB-3’s outbound impacts and the ripple effects across the system: CAMT interactions and credit ordering; Section 174 R&E expensing elections; Section 163(j) excluding CFC items and the financing/on-lending response; FDII’s shift to FDDEI, a permanent 14% rate, and 2026 expense-apportionment relief; GILTI’s rebrand to Net CFC tested income with a 14% effective rate and ‘directly allocable’ expense questions; inventory-sourcing relief; repeal of the Section 898 one-month deferral; permanent CFC look-through; the Section 958(b)(4) fix; a new Section 951(a)(2)(B) framework; selected technical corrections; and why granular modeling matters now more than ever.

One Big Beautiful Podcast, Part 4: Inbound Edition

Wed, 27 Aug 2025 15:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Nita Asher, an international tax principal in PwC’s Washington National Tax Services practice focused on inbound multinationals, with prior government experience during the TCJA. Doug and Nita discuss the One Big Beautiful Bill Act (“OB3”) and its impact on inbounds, including permanent 100% bonus depreciation; new Section 168N for qualified production property; Section 163(j)’s EBITDA-based ATI; the reworked ‘FDDEI’ (formerly FDII) and its 14% rate with outbound IP limits; shifting IRA credit timelines and ‘foreign entity of concern’ issues; BEAT’s modest rate bump to 10.5% and unchanged credit treatment; the potential future of Section 899; and CAMT interactions. Throughout, they emphasize modeling to avoid BEAT/CAMT whipsaws while capturing OBBBA cash-flow benefits.

Pillar Two Hybrid Arbitrage: stormy waters ahead?

Thu, 21 Aug 2025 10:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Raza Janjua, a Director in PwC’s ITS practice in New York and author of a recent article on Pillar Two hybrid arbitrage arrangements. Doug and Raza discuss the BEPS Action 2 origins and ATAD 2 implementation; how Pillar Two’s simplified safe harbors spawned detailed hybrid arbitrage rules; the core categories—deduction–non‑inclusion, duplicate loss, and duplicate tax recognition; real‑world traps like preferred equity treated as book debt, FX‑driven mismatches, valuation‑allowance hypotheticals, cash pools and back‑to‑backs; narrow dual‑inclusion relief and why it should be jurisdiction‑level; CFC‑regime interactions; retroactivity and early adoption; and what future administrative guidance and the G7 architecture could mean for US rules such as Sections 245A(e), 267A, and the DCL regime.

Geopolitics, Protectionism, and the Future of Global Commerce

Tue, 12 Aug 2025 14:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by returning guest Craig Stronberg, Senior Director of PwC Intelligence. Craig previously had a near 20-year career in National security affairs before joining PwC. Craig and Doug discuss changes to US global policy and protectionism; the rise of new global powers and alliances; the growing divide between developed and developing countries regarding global tax policy; the debate over globalization’s benefits; and the current trade environment. They also discuss how multinational companies are responding to uncertainty, deploying corporate risk management, scenario planning, and gaining competitive advantages.

Careers in tax: Two international tax titans

Tue, 29 Jul 2025 15:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Mike Urse and Calum Dewar, both retiring PwC International Tax partners with decades-long careers in cross-border tax. Mike served as PwC’s US ITS Leader, while Calum built his career across PwC UK and PwC US, specializing in European and global tax systems. Doug, Calum and Mike discuss the dynamic nature of international tax and the intellectual curiosity that drew them to the profession. They also reflect on the evolution of PwC’s international tax practice, consensus-driven leadership, and building high-performing teams. The trio shares stories on mentorship, the impact of technology - from dictaphones to AI - and how global tax reform has shaped the practice. With humor and candor, they offer career advice to current and future tax professionals and celebrate the relationships, challenges, and learning that have defined their time at PwC.

One Big Beautiful Podcast, Part 3: Return of the G7

Thu, 17 Jul 2025 16:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Pat Brown, an international tax partner and Co-Leader of PwC’s Washington National Tax Services practice and former US Treasury’s Associate International Tax Counsel. In part three of Doug’s three-part OBBBA discussion with Pat, they discuss the newly enacted OB3 reconciliation law, focusing on its permanent corporate and individual tax provisions, the recalibration of bonus depreciation, Section 174 expensing and Section 163(j); the Senate’s redesign of GILTI, FDII and BEAT; Inflation Reduction Act rollbacks; Treasury’s last-minute removal of Section 899; and the G7’s surprise accord intended to exempt US-parented groups from Pillar Two’s IIR and UTPR while elevating QDMTTs and compliance simplification. They map the procedural and legislative steps still needed, potential timing gaps, and why multinational groups must keep Pillar Two compliance front-of-mind.

Pillar Two in Asia-Pac: Still happening

Tue, 08 Jul 2025 12:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Jesse Kavanaugh, an international tax partner at PwC Hong Kong who leads Tax Reporting & Strategy and co-heads PwC’s Asia-Pacific Pillar Two team. Formerly the global head of tax operations for a US tech multinational, Jesse brings both in-house and advisory insights. Doug and Jesse discuss the uneven rollout of Pillar Two across nine Asia-Pac jurisdictions; China, India and US uncertainties; Hong Kong’s Pillar Two legislation (pending when this podcast was recorded, but enacted on June 6, 2025) and HKMTT design; why many countries are shelving the UTPR; looming QDMTT deadlines; the critical difference between data-gathering and calculation engines; pitfalls that blow up transitional safe harbors, including management accounts, hybrid loans, interest-free debt and purchase-price accounting; and industry-specific challenges for shipping, airlines and real estate. Jesse closes with a simple message: start compliance prep now…registration and early QDMTT filings wait for no one.

One big beautiful podcast: Part 2

Thu, 26 Jun 2025 14:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined on June 24, 2025, by Pat Brown, an International Tax Partner and Co-Leader of PwC’s Washington National Tax Services practice. Pat previously served as the US Treasury’s Associate International Tax Counsel and has been a frequent guest on the podcast. Doug and Pat start where they left off discussing 'One Big Beautiful Bill' (OB3), in wake of the US Senate Finance Committee Chairman's Substitute Amendment. They discuss the next steps in the legislative timeline including the impending July 4th deadline, the impact of the Byrd rule, as well as the many changes to both the business and international provisions. They focus on the major changes to Section 899, global intangible low-taxed income (GILTI), foreign derived intangible income (FDII), and the base erosion and anti-abuse tax (BEAT).

One big beautiful podcast: Part 1

Mon, 16 Jun 2025 10:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Pat Brown, an International Tax Partner and Co-Leader of PwC’s Washington National Tax Services practice. Pat previously served as the US Treasury’s Associate International Tax Counsel and has been a frequent guest on the podcast. Doug and Pat discuss the legislative and international tax implications of the 'One Big Beautiful Bill', including its procedural path through US Congress under budget reconciliation, and its implications for both domestic and cross-border taxpayers. They explore the bill’s temporary business provisions, including TCJA 'orphan' fixes, and the evolving treatment of research expenses, bonus depreciation, and interest deductions. A major focus is Section 899—dubbed the 'super BEAT'—which targets foreign digital services taxes (DSTs), diverted profits taxes (DPTs), and Pillar Two’s undertaxed profits rule (UTPR) with steep retaliatory measures. They also analyze the international negotiations around UTPR exemptions, the impact on treaty obligations, and the ongoing debate over treatment of US tax credits—particularly the R&D credit—under global minimum tax rules.

China Tax Update: Tariff turmoil and treaty tensions

Wed, 04 Jun 2025 15:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Jenny Chong, Shanghai-based International Tax Partner and PwC’s Asia-Pacific International Tax Services Leader. Doug and Jenny discuss the structure and enforcement of China’s international tax regime, including corporate tax rates, incentives, CFC rules, and foreign tax credits. They examine the complexities of indirect stock transfer rules, audit trends, and beneficial ownership requirements. The conversation turns to Pillar Two, where Jenny outlines how Chinese multinationals are preparing despite a lack of formal adoption. They also explore the implications of potential termination of the US-China tax treaty and the resurgence of tariffs. Jenny shares how Chinese companies are adapting to compliance burdens and regulatory uncertainty amidst global tax and trade tensions.

When Purpose Meets Tax: How Teams Can Transform

Wed, 21 May 2025 13:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Leo Johnson, lecturer at Oxford University’s Smith School of Enterprise and the Environment. Leo is also co-founder of the advisory firm Sustainable Finance, where he chairs the Advisory Council, and previously worked at the World Bank. Known for presenting the BBC series on megatrends and innovation. Leo brings unique insight into organizational behavior, neuroscience, and purposeful leadership.

Doug and Leo discuss organizational inertia, transformation resistance, and how neuroscience and behavioral science explain our resistance to change—even amid crises like climate change, geopolitical turmoil, and economic stress. They explore how professionals, including those in international tax, can overcome ‘learned helplessness’ and avoid burnout by embracing purpose, agency, and connectedness. Leo introduces the concept of behavioral personas within organizations—catalysts, silent rebels, workhorses, and sustaining innovators—and emphasizes the need for authentic engagement and collaboration to drive meaningful change.

Itai Grinberg: The Pillar Two origin story (part 2)

Tue, 06 May 2025 12:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Professor Itai Grinberg, a faculty member at Georgetown University Law Center and a former Deputy Assistant Secretary at the US Treasury Department during the Biden administration. In that role, Itai served as the United States' lead negotiator for the global corporate minimum tax initiative. Doug and Itai discuss the behind-the-scenes history of Pillar Two from the US perspective, exploring its policy rationale, global negotiations, and shifting political dynamics. The conversation begins with how Itai’s got his role at Treasury and builds a detailed timeline tracing the Biden administration’s early support for global minimum tax rules through the 2021 G7 agreement and the development of the Under-Taxed Profits Rule (UTPR). They also delve into the impact of the Build Back Better legislation which was not enacted, the rationale behind the US safe harbor under UTPR, international political tensions including Brexit and US-China relations, and the implications of the April 2025 Trump executive order. The episode closes with reflections on the OECD Inclusive Framework’s future and whether multinational enterprises can expect a workable consensus moving forward.

German Tax Update: Freshly served

Wed, 23 Apr 2025 15:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Arne Schnitger, a Berlin-based International Tax Partner at PwC Germany and co-host of the German-language tax podcast “Frisch Serviert.” Arne previously served in the German Ministry of Finance and brings deep insight into both domestic and cross-border policy developments. Doug and Arne discuss Germany’s evolving corporate tax landscape, including potential rate reductions, simplification initiatives, and the implications of recent coalition negotiations. They dive into Germany’s controlled foreign corporation (CFC) regime, explore the mechanics of the constitutional ‘German debt brake,’ and unpack recent developments surrounding Pillar Two. The conversation highlights the intersection of German and US tax policy, the ongoing tension between multilateralism and unilateral measures, and the administrative and technical challenges multinationals face under the global minimum tax framework. They also examine prospects for EU-level simplification and the future of long-standing anti-avoidance measures in light of Pillar Two implementation.

Withholding retaliation? US Sections 891 and 899

Tue, 08 Apr 2025 14:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Tom Patten, a London-based US International Tax Partner at PwC. Tom focuses on inbound investment into the U.S. and returns to the podcast for a timely discussion on Sections 891 and 899, two lesser-known but increasingly important provisions in the international tax landscape. Doug and Tom discuss the resurgence of Section 891 in light of a January 2025 executive order that directs Treasury to identify discriminatory or extraterritorial foreign taxes. They cover how Section 891 operates, potential implications for non-US citizens, and its interaction with treaties. The episode then turns to proposed Section 899 and a new House proposal aimed at modifying the base erosion and anti-abuse tax (BEAT). Tom and Doug examine how these retaliatory measures differ, overlap, and might evolve. They close with practical advice for multinational taxpayers navigating an uncertain legislative environment and the future of Pillar Two negotiations.

Brazil Tax Update: Full inclusion to full immersion

Wed, 02 Apr 2025 12:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Dr. Romero Tavares, PwC Brazil’s International Tax Leader and a professor of international tax law in São Paulo. Doug and Romero discuss the increasing intersection between Brazil’s international tax policy and global trade dynamics, including the effects of recent US executive orders. They cover Brazil’s high-tax corporate environment, its historically aggressive CFC-like full inclusion regime, and the country’s rapid adoption of a qualified domestic minimum top-up tax (QDMTT). The conversation explores the political and policy rationale behind these moves, the anticipated redesign of Brazil’s CFC regime, and the operational challenges multinationals face with the new OECD-aligned transfer pricing rules. Romero also breaks down Brazil’s massive indirect tax reform and the country’s potential shift to more internationally-aligned tax norms, while questioning the long-term viability of the undertaxed profits rule (UTPR) and Pillar Two’s durability under changing geopolitical winds.

The Great Economic Reordering: What’s Next for Global Markets?

Thu, 20 Mar 2025 13:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Dr. Alexis Crow, Partner and Chief Economist at PwC US. Before joining PwC, Dr. Crow taught at the London School of Economics. Doug and Alexis discuss the intersection of global macroeconomics, geopolitics, and international tax policy in a shifting global landscape. They break down the impact of the Trump administration’s latest tariffs on Canada and Mexico, inflationary pressures, interest rates, and the fiscal cliff facing the US.

Doug and Alexis explore how the geopolitical climate is shaping international trade, the potential winners and losers of increased tariffs, and the broader economic implications of Trump 2.0. They also analyze regional macroeconomic trends, from China’s economic resilience and India's manufacturing rise to Europe's fiscal strategies and Latin America’s economic experiments. Lastly, they discuss how businesses—particularly multinationals—should be preparing for upcoming policy shifts and economic disruptions.

Tariff Tango: What’s next for global business?

Wed, 12 Mar 2025 14:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Kristin Bohl, a Partner in PwC’s Customs and International Trade Practice. Kristin previously served as a judicial law clerk at the U.S. Court of International Trade. Doug and Kristin discuss the rapidly evolving trade and tariff landscape, focusing on the recent executive orders imposing new tariffs on Canada, Mexico, and China under the ‘America First’ trade policy. They break down the impact of tariffs on industries such as automotive, pharmaceuticals, retail, and technology, and cover strategies that businesses can deploy to mitigate costs. Key topics include the authority of the US President to impose tariffs, the role of trade deficits in tariff policy, and the use of tariffs as a foreign policy tool. They also explore potential retaliatory measures from US trading partners, the impact on global supply chains, and short to long-term strategies for businesses to adapt to the new tariff regime.

US Tax Policy: What’s Staying, What’s Going, and What’s Next?

Thu, 27 Feb 2025 14:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Pat Brown, an International Tax Partner and Co-Leader of PwC’s Washington National Tax Services practice. Together, they unpack the state of US corporate tax policy in 2025, analyzing how regulatory, legislative, and geopolitical forces could shape the next era of taxation. Doug and Pat dissect the final regulations issued in the closing days of the Biden administration, including the controversial disregarded payment loss (DPL) regulations, finalized and proposed digital content and cloud sourcing rules, and updates on corporate basis-shifting transactions. With a new administration in power, they explore whether these rules will stand, be modified, or be repealed entirely—and what this means for business certainty and planning. The conversation then pivots to legislative challenges, as the expiration of key provisions from the 2017 Tax Cuts and Jobs Act (TCJA) creates a ticking time bomb for tax policy. Finally, they tackle the international tax front, where the US f administration responds to the OECD’s Pillar Two and potential digital services tax (DST) retaliation under new proposals like Section 899.

Pillar Two: Administrative Guidance Part 5

Thu, 20 Feb 2025 13:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Steve Kohart, an International Tax Principal in PwC’s New York City office and former advisor to the OECD’s Center for Tax Policy and Administration. Doug and Steve discuss the OECD’s latest administrative guidance on Pillar Two, covering key changes to transition rules, deferred tax asset adjustments, tax credits, and compliance burdens for multinational corporations. They dive into the OECD’s focus on Bermuda and Switzerland, new anti-abuse measures, implications of the Qualified Domestic Minimum Top-up Tax (QDMTT), and the complexities of the new Globe Information Return (GIR). The conversation also explores the political and procedural challenges in implementing additional guidance, particularly in light of the new US administration’s stance on Pillar Two.

Finally final: The US Section 987 FX regs

Thu, 06 Feb 2025 12:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Rebecca Lee, an International Tax Principal in PwC’s Washington National Tax Services practice. Rebecca specializes in financial transactions and digital assets and is one of the most frequent guests on the podcast. Doug and Rebecca discuss the long-awaited final and proposed regulations under Section 987, which deal with foreign currency gain or loss for qualified business units (QBUs). They dive into key topics, including methods for calculating 987 gains and losses, the transition rules, applicability dates, and the implications of different election options. They also cover major changes from the proposed to final regulations, including adjustments to the treatment of Section 988 transactions within a QBU, tax accounting considerations, the controversial suspended loss rules, and how partnerships are impacted.

From Pillar Two to Transparency: A Tax Executive’s Perspective

Wed, 29 Jan 2025 11:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Tadd Fowler, Senior Vice President Treasurer and Global Taxes of Procter & Gamble. With nearly two decades at P&G, Tadd shares insights from his dual leadership in tax and treasury. Doug and Tadd discuss P&G’s approach to tax certainty, compliance in over 180 jurisdictions, and the strategic benefits of operating on a single ERP platform. They delve into US tax policy, the impacts of the Tax Cuts and Jobs Act, and P&G’s commitment to transparency and tax advocacy. Additional topics include preparing for Pillar Two compliance, managing ESG taxation, and adapting to evolving global tax landscapes. See P&G’s Approach to Tax.

US Update: the long-awaited PTEP regs

Wed, 22 Jan 2025 14:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Laura Williams, an International Tax Principal at PwC’s Washington National Tax Services office. Laura previously worked as the International Branch Chief at the IRS Office of Chief Counsel. Doug and Laura discuss the long awaited previously taxed earnings and profits (PTEP) proposed regulations. Together they walk through the core aspects of the PTEP regime, including PTEP accounting, increases and decreases to basis of stock and other property, foreign currency gain or loss, allocation of foreign tax credits, 'covered distributions’, US consolidated group rules, and the anti-avoidance rule. See our PwC Tax Insight for more details.

Global tax policy: searching for stability and certainty

Wed, 08 Jan 2025 11:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Will Morris, PwC’s Global Tax Policy Leader and former Director of Global Tax Policy at General Electric to look ahead to potential global tax policy changes. Will enlightens Doug about the confluence of tax and tariffs, digital services taxes (DSTs), the importance of communicating with the C-suite, the fate of Pillar Two, how the undertaxed profits rule (UTPR) could change, the role of the UN and global tax, and the potential for a US legislation as a reaction to DSTs and the UTPR.

Accounting for Pillar Two: More than a tax exercise

Thu, 19 Dec 2024 10:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Andy Wiggins, PwC Partner based in the United Kingdom and PwC’s Global Tax Accounting Services Leader to(birming)ham it up on the tax accounting implications of Pillar Two. Together they discuss, deferred accounting, the differences between US Generally Accepted Accounting Principles (GAAP) and International Financial Reporting Standards (IFRS), accounting implications of the qualified domestic minimum top-up tax (QDMTT), income inclusion rule (IIR), and undertaxed profits rule (UTPR), country by country reporting (CbCR), and transitioning from the full safe habor to GloBe rules.

Pillar Two: UK update

Thu, 12 Dec 2024 14:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by returning guest Matt Ryan, a PwC International Tax Partner based in London and leader of PwC UK’s International Tax and Treasury Network. Doug and Matt discuss a selective list of Pillar Two issues and topics related to the UK Finance Bill 2024-25. They provide an update on the latest Pillar Two happenings, including the transposition of the June 2024 OECD Administrative Guidance into UK law, the potential for retroactive provisions, UK compliance requirements, the potential for changes in light of the US election, and what could be next.

Pillar Two around the World: Country updates

Fri, 06 Dec 2024 10:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Stewart Brant, Managing Director in PwC’s Tax Policy Services to discuss the latest Pillar Two developments. Doug and Stewart start off – after baseball of course – discussing the purpose of the Digital Tax Study Group. Then they cover the status of Pillar Two enactment in Europe, Asia, the Americas, the Pacific, the Caribbean, Middle East, and Africa. They also cover how different countries are applying the rules retroactively, the impact a Trump administration could have on Pillar Two, as well as what role the UN could play.

US Election Results: What’s next for tax

Wed, 20 Nov 2024 14:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Rohit Kumar, PwC’s National Tax Co-leader and former deputy chief of staff to Senator Mitch McConnell (R) to discuss the US election results. Doug and Rohit cover what the republican-controlled House, Senate and Presidency means for tax reform, why 2025 will be a year for significant “must-pass” tax legislation, the role the federal debt and budget deficit will play, the potential implementation of tariffs, the fate of the OECD’s Pillar One and Two, as well as how the new administration could approach digital services taxes (DSTs).

Pillar Two in Belgium: First out of the gate

Thu, 14 Nov 2024 12:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Pieter Dere, Tax Partner in PwC Belgium, part of PwC’s International Tax and Transfer Pricing Group, and PwC Belgium’s Pillar Two leader. Doug and Pieter cover the latest Pillar Two developments in Belgium, including how Belgium is incorporating the latest Pillar Two administrative guidance, how tax authorities are preparing, advance tax payments, registration requirements, the Qualified Domestic Minimum Top-up Tax (QDMTT) return, the interaction of the Belgium patent box regime with Pilar Two, and the constitutionality of the Undertaxed Profits Rule (UTPR), among other topics.

Tariffs  and Taxes:  Retaliation & Retribution

Thu, 31 Oct 2024 15:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Chris Desmond, PwC’s US Global Trade Services Leader to catch up on the latest customs and trade happenings. Doug and Chris talk about Chris’s transition from a transfer pricing partner to specializing in customs and trade, the potential US tariffs environment post election, how companies might respond with supply chain changes, the impact of the recent Mexican and Canadian tariffs, the use of tariffs as a retaliatory action, how tax authorities are leveraging customs data, as well as the importance of modeling, documentation, and data gathering.

Pillar Two Update: Traps for the unwary

Wed, 23 Oct 2024 16:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by returning guest Steve Kohart, an International Tax Partner in PwC’s New York City office and former advisor to the Center for Tax Policy Administration for the OECD. They dive into Pillar Two with a refresher of the Qualified Domestic Minimum Top-up Tax (QDMTT), the Income Inclusion Rule (IIR), the Under Tax Profit Rule (UTPR), as well as the status of Pillar Two enaction across the globe, including in Puerto Rico. They also talk through how companies are approaching year-end, data readiness and tax compliance; Belgium’s registration process; and several traps for the unwary, including the post-finalization of consolidated financial statements, purchase price accounting, hybrid arbitrage, and country-by-country safe harbor requirements. Finally, they discuss what makes a ‘good’ credit for Pillar Two, the US R&D credit, the reverse consensus process for qualifying a QDMTT, permanent safe harbors, and what guidance to expect next.

US CAMT Proposed Regs: You are no Pillar Two

Fri, 11 Oct 2024 12:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by returning guest Aaron Junge, an International Tax Partner in PwC’s Washington National Tax Services Practice. Aaron served as Tax Counsel to the US House of Representative during the passing of the Tax Cuts and Jobs Act in 2017. Doug and Aaron briefly discuss the College World Series held in Aaron’s hometown of Omaha, before delving into the Corporate Alternative Minimum Tax (CAMT) proposed regulations. Specifically, they discuss Adjusted Financial Statement Income (AFSI), how the rules affect large domestic and foreign investment funds and partnerships, the open comment period, the similarities (and differences) between CAMT and Pillar Two, whether or not CAMT could be converted to a QDMTT, how the regulations impact adjustments for depreciation, and new foreign stock rules.

Business Model Reinvention: Tax Implications

Wed, 25 Sep 2024 14:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by returning guest Alex Voloshko, an International Tax Partner in PwC’s Washington National Tax Services Practice where he specializes in value chain transformation and the tax implications of business operating models. Doug and Alex discuss how tax interacts with the broader business, the evolution of the tax operating model, business model reinvention, the importance of data, supply chain management, IP trends from the 2017 TCJA, and the potential impact of Pillar Two.

No double dipping! US proposes new regulations

Fri, 13 Sep 2024 12:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by returning guest Elizabeth Nelson, a Partner in PwC’s Washington National Tax Services Practice to discuss the recently proposed regulations that address dual consolidated loss (DCL) rules as well an entirely new tax regime regarding disregarded payment losses (DPLs). Together they dive into the background of the US DCL rules, effective dates, foreign use, intercompany transactions, stock inclusions, mirror legislation, a new anti-avoidance rule, and of course the application of the DCL rules to Pillar Two.

Taxing Cryptocurrency: US Digital Asset Regs

Wed, 28 Aug 2024 16:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by returning guest Rebecca Lee, a Principal in PwC’s Washington National Tax Services Practice where she focuses on complex tax problems and financial transactions in the digital asset space. Doug and Rebecca discuss T.D. 10000, the recently published final regulations dealing with digital assets. They dive into the details of digital assets, including the definition of a digital assets, revisiting non-fungible tokens (NFTs) and blockchain, and the different types of digital transactions. They also cover the background of the final regulations, calculating gains and losses, determining basis, digital asset transaction costs, ordering rules, Form 1099-DA, Notices 2024-56 & 2024-57, and the applicability dates. They finish the podcast with an exploration of how other jurisdictions are approaching cryptocurrencies around the world, touching on FATCA, DAC8 and more.

US Election Watch: Tax Implications

Wed, 14 Aug 2024 13:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Janice Mays (Managing Director in PwC’s Tax Policy Services) who boasts a 40 year career on the Hill including 22 years as the Democratic chief counsel and staff director for the House Ways and Means Committee, to discuss the upcoming US election’s impact on tax policy. Doug and Janice dive into the practice and procedures behind US tax policy, the upcoming US presidential election, and the key races to watch in the US Senate and House of Representatives. They also cover various election result scenarios, the key priorities for both Republicans and Democrats in a 2025 tax bill, and a potential US reaction to Pillar Two.

US Supreme Court Update: Chevron is no Moore

Tue, 30 Jul 2024 21:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Wade Sutton, International Tax Leader for PwC’s Washington National Tax Practice. Doug and Wade kick off with the persona of a law school professor, providing an overall perspective on the US common law system, and how the US court system works. They then cover the importance three of Supreme Court’s recent tax case decisions – Moore v. United States, Corner Post v. United States, & Loper Bright v. United States. They start by ‘briefing’ the cases before noting why taxpayers should pay attention to each case. Additionally, they cover a potential wealth tax, the possible effects of the cases on litigation and tax controversy, what constituted the majority opinion in Loper Bright, the overruling of the Chevron doctrine, and regulatory validity.

Pillar Two Admin Guidance Glimpses of clarity

Wed, 17 Jul 2024 16:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Phil Ramstetter, International Tax Partner and former Tax Policy Consultant at Business at OECD (BIAC). Doug and Phil discuss the OECD’s Administrative Guidance released in June 2024, including the deferred tax liability (DTL) recapture rule or five-year rule, the allocation of cross-border taxes, deferred tax accounting, transactions within the GloBE rules, entity classification and treatment, and the expectation of more OECD administrative guidance in the second half of 2024.

US Stock Buyback Tax: a funding conundrum

Wed, 26 Jun 2024 12:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Nita Asher, International Tax Partner in PwC’s Washington National Tax Practice and former legislative counsel to the Joint Committee of Taxation during the enactment of TCJA in 2017. Doug and Nita focus on the Stock Buyback Excise Tax enacted under the Inflation Reduction Act. Doug and Nita walk through Notice 2023-2, the recently released procedural and technical regulations, including the elimination of the per se rule, the funding rule, and which other countries are considering similar rules. They also discuss how the excise tax could present a multi-year reporting exercise for taxpayers, utilizing Forms 720 and 7208. Non-US headquartered companies will be very interested in this conversation!

Pillar Two Potpourri: Where is this heading?

Wed, 12 Jun 2024 11:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is with Pat Brown, Washington National Tax Services Co-Leader, to discuss the complex state of international tax today and where the winds of Pillar Two are blowing. Doug and Pat bare their ankles and kick off the discussion with the state of international tax when Pat graduated law school. They cover the increasing complexity of tax regimes, before diving into Pillar Two, the Undertaxed Payments Rule (UTPR), qualified CbC reporting, business concerns and struggles, the United Nations’ role in international tax, and recently published Belgian Pillar Two registration requirements.

Pillar Two in Ireland: It takes a village

Thu, 30 May 2024 11:00:00 -0400

Doug McHoney (PwC's Global International Tax Services Leader) and Peter Reilly (PwC International Tax Partner & Ireland’s Tax Policy Leader) are at PwC EMEA’s International Tax Academy in Prague to discuss Ireland’s implementation of Pillar Two. Doug and Peter dive into why Irish policy makers agreed to adopt the Pillar Two regime, how Ireland is incorporating the OECD guidance, the potential effects on the Irish economy and current tax regime, the ways Irish multinationals are preparing, and the potential ramifications in the future.

Pillar Two: Hindsight is 20/24

Fri, 10 May 2024 15:00:00 -0400

Doug McHoney (PwC's Global International Tax Services Leader) and podcast regular Calum Dewar (Principal, International tax services) are at PwC’s EMEA’s International Tax, Legal, and Workforce Academy in Prague, Czech Republic, to discuss the latest happenings around Pillar Two. Doug and Calum examine the many practical issues taxpayers, governments and tax advisors are facing to implement the new rules, including disparity in financial accounting, the QDMTT safe harbour, arbitrage arrangements, GloBE reorganization rules, and allocation of deferred taxes.

Pillar Two Data Strategy: Play ball!!!

Mon, 29 Apr 2024 14:00:00 -0400

Doug McHoney (PwC's US International Tax Services Global Leader) is with Anthony Sciarra, a Principal in PwC’s Tax Reporting and Strategy Practice and the Global Pillar Two Data Strategy leader, to discuss the importance of a Pillar Two Data Strategy. Doug and Anthony detail what taxpayers should be doing today to stay ahead of Pillar Two’s complexity, specifically highlighting: data sourcing, data forecasting, qualifying for the CbC Transitional Safe Harbor, considerations for both an insourcing & outsourcing model, existing technology solutions, and the importance of a centralized rules calculation.

As the world turns: Macroeconomic trends

Tue, 09 Apr 2024 21:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s International Tax Conference in Dana Point, California with Dr. Alexis Crow, PwC’s Geopolitical Investing Practice Leader. Doug and Alexis discuss the recession outlook and economic activity, the impact of inflation, central banking policy, including interest rates, commercial real estate and financial stability, currencies and the future of the US Dollar, energy transition, the US election outlook, and outlooks for some significant economies, including Japan, India, Singapore, Brazil, the Middle East, and Europe.

Brazil Tax Reforms: muito complicado!

Tue, 26 Mar 2024 16:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is in São Paulo, Brazil for the first Latin American recording of the CBTT with PwC Brazil’s International Tax Leader Dr. Romero Tavares. Doug and Romero discuss what makes Brazil’s tax system so unique – from its transfer pricing rules to its full inclusion regime. They also dive into expected Brazilian tax changes, the many acronyms that make up the indirect tax system, Pillar One, and what effect Pillar Two will have on Brazil’s taxpayers.

US Tax Policy: Chairman Dave Camp

Thu, 14 Mar 2024 08:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s International Tax Conference in Dana Point, California with former House Ways & Means Chairman Dave Camp, now senior policy advisor in PwC’s Washington National Tax Services. Doug and Chairman Camp discuss his political career, drivers behind US tax policy, how Congress negotiates tax legislation, the expiring provisions in the Tax Cuts & Jobs Act (TCJA), the prospects of Congress implementing Pillar Two in the years ahead, and how companies can get involved in the tax legislative process.

Geopolitics Unraveled: Trends for 2024

Wed, 28 Feb 2024 05:00:00 -0500

In this episode of Cross-Border Tax Talks, Doug McHoney interviews Craig Stronberg, a Senior Director in PwC's Intelligence Team, about major geopolitical trends impacting business leaders and the operating environment. They discuss topics such as protectionism, the US-China rivalry, distrust, the shift in global power, tech disruption, labor, and the Middle East. They also highlight the importance of business leaders taking stock of lessons learned from the COVID-19 pandemic and the potential risks associated with the ongoing conflict in Ukraine.

US Guidance Update: Pillar Two and more

Tue, 13 Feb 2024 15:00:00 -0500

On this episode, Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Wade Sutton. Wade is PwC’s Washington National Tax Service’s ITS Leader, a former adjunct professor of international tax at Georgetown University's Law Center, and former Deputy International Tax Counsel, US Treasury. Doug and Wade discuss what drove them to international tax as a career (spoiler: job security) before diving into recent US tax guidance. They discuss the recent foreign tax credit (FTC), corporate alternative minimum tax (CAMT) and Previously taxed E&P (PTEP) notices. They also discuss the interaction of Pillar Two with the FTC rules, dual consolidated loss (DCL) rules, and CAMT. Doug and Wade wrap up by looking ahead to guidance we might see in 2024.

Sustainability and Transparency for Tax Professionals

Tue, 06 Feb 2024 04:00:00 -0500

In this podcast episode, Doug McHoney, PwC’s International Tax Services Global Leader, interviews Heather Horn, PwC's Assurance National Thought Leader and host of the twice-weekly PwC Accounting Podcast. Doug and Heather discuss sustainability reporting and its increasing importance in the business world. They cover various regulations and standards, such as the EU’s Corporate Sustainability Reporting Directive (CSRD), and the potential intersection between sustainability reporting and tax transparency. Doug and Heather note the similarities between CSRD and other recent reporting requirements, like Pillar Two and the EU’s Foreign Subsidies Regulation (FSR). They also highlight the challenges and considerations for companies as they deal with new stakeholders and navigate the new reporting requirements.

Pillar Two: how safe is the safe harbor?

Wed, 24 Jan 2024 14:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Steve Kohart for our first podcast in PwC’s New York studio. Steve is a PwC international tax partner based in New York, and a former adviser for the OECD Center for Tax Policy and Administration. Doug and Steve discuss the OECD’s latest Pillar Two Administrative Guidance, which was published December 18, 2023 and primarily covers the transitional country by country Safe Harbor. More specifically, Doug and Steve address how jurisdictions will implement the guidance, purchase price accounting adjustments, consistent use of data, hybrid arbitrage arrangements, the allocation of CFC taxes, and whether the OECD will provide additional guidance in 2024.

Gen AI in Tax: a new frontier

Thu, 04 Jan 2024 05:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s Tax Leadership Conference in breezy Orlando with Dom Megna, a New York-based tax partner leading PWC's US Tax Reporting and Strategy Practice. Doug and Dom discuss Artificial Intelligence (AI) and its place in tax. They focus on four areas - what is conversational AI, machine learning, deep learning, and generative AI (a subset of deep learning). They also cover some impacts of AI: AI for tax practitioners, how AI will affect people’s jobs, data opportunities and architecture, Pillar Two, responsible AI, and the ROI of AI.

Taxing FX of Branches: the new Section 987 regulations

Tue, 19 Dec 2023 14:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Rebecca Lee (WNTS ITS Partner) in PwC’s Washington, DC studio for the 140th (and Rebecca’s) episode of the Cross-Border Tax Talks podcast. Rebecca, a frequent guest on the podcast, specializes in financial transactions and digital assets. Doug and Rebecca discuss the history and intent of Section 987, which is generally to address the taxation of foreign exchange gains/losses from a foreign branch operating in a different functional currency than its home office. The rules started out relatively simply at three sentences, but since enactment we’ve received 100s of pages of regulations. Doug and Rebecca discuss how the layers of complication led to confusion and concerns over policy and administrability. This background is critical to understanding the challenges companies are facing today with the November 2023 proposed regulations. Doug and Rebecca dissect and analyze the 250-page package, what new elements and limitations they introduce, and what this means for affected companies, including industries like banking and insurance. They close the discussion with how the effective dates work and why the operation of these rules may have surprising results.

UK Pillar Two: Painting while the paint dries

Tue, 12 Dec 2023 12:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Matt Ryan at PwC’s Global Tax Symposium in Rome. Matt is a London-based international tax partner and PwC UK’s Pillar Two Leader. Doug and Matt revisit the UK Pillar Two rules for the third time, but now from an enacted law perspective. While the rules are set to apply from the beginning of 2024, the United Kingdom faces an interesting challenge as one of the early adopters of Pillar Two, with enacted legislation, followed by additional OECD guidance. Doug and Matt discuss the tricky task for UK legislators of ‘painting while the paint still dries’ (i.e., enacting legislation while the OECD guidance is still changing) and some of the key differences that need to be addressed as a result of the subsequent OECD guidance, as well as still-expected guidance in 2023 and beyond. Doug and Matt discuss from a practical perspective how UK-parented taxpayers are preparing for what is ahead, including approaches to safe harbors. They then dive into complexities created by the particularities of the UK rules around the safe harbor and other key issues, like partnerships and deferred taxes. Finally, the podcast closes with practical next steps companies operating in the UK should consider ahead of 2024.

Pillar Two: Policy, politics and interaction with Pillar One

Thu, 07 Dec 2023 19:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s Global Tax Symposium in Rome, where he’s joined by Will Morris. Will is PwC’s Global Tax Policy Leader, and on Will’s last visit to the podcast, he covered FSR, the Foreign Subsidies Regulation. On this podcast, an exciting and familiar topic - Pillar Two! Doug and Will discuss generally how the Pillar Two process has been going. They wonder how tax authorities and courts will administer and adjudicate in their jurisdictions, and what will become of the potential FAQs and future administrative guidance from the OECD. They then discuss the recent EC guidance, and whether countries will be able to bring in the OECD guidance retroactively. Finally, Doug and Will touch on how business have participated thus far in the process.

Pillar One: Policy, politics and interaction with Pillar Two

Thu, 30 Nov 2023 10:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s Global Transfer Pricing Conference where he’s joined by Giorgia Maffini. Giorgia is part of PwC’s Global Transfer Pricing team in London and was previously the Deputy Head of the Tax Policy and Statistics Division at the OECD. Doug and Giorgia discuss why taxpayers should care about Pillar One, starting with the basics - what is Pillar One and how does it work with Pillar Two? They discuss the complexities, scope and impacts of both Amount A and Amount B. Also the timing, economic impact, and what’s next. Finally, they address what might happen with digital services taxes and what companies should do next.

Pillar Two Safe Harbors: The CbCR journey

Wed, 15 Nov 2023 09:00:00 -0500

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by David Ernick, a Principal with PwC’s Washington National Tax Services Transfer Pricing Practice and former Associate International Tax Counsel at the US Treasury Department, at PwC’s Global Transfer Pricing Conference in San Diego, California. They discuss Country-by-country reporting (CbCR) transitional safe harbor rules, including the safe harbor tests, exclusions to the rules, the difference between the safe harbor rules and the full GLoBE rules, as well as whether a CbCR is ‘qualifying’. Doug and David also discuss the history and implementation of public CBCR.

On notice: US developments and Moore hype

Mon, 30 Oct 2023 16:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s Tax Leadership Conference in breezy Orlando with Pat Brown, frequent pod guest and co-leader of PwC’s Washington National Tax Services. They discuss US tax updates, including the status and fate of the Tax Cuts and Jobs Act (TCJA); the future of Section 163(j); notices and guidance from Treasury, including the recent Section 174 notice 2023-63; FTC relief notice, and what to anticipate in the coming months and years with respect to foreign tax creditability; what’s included and what’s not included under the corporate alternative minimum tax (CAMT); Section 367(b) ‘Killer B’ regulations; and the Moore case.

Trick or treat(y): An update on US treaties

Wed, 04 Oct 2023 15:00:00 -0400

Doug McHoney (PwC’s International Tax Services Global Leader) is back in Westminster Studios in St. Louis, Missouri with Nils Cousin, a Washington, D.C. based International Tax Services Principal specializing in US inbound taxation. Together they discuss tax treaties, mutual agreement procedures, the concept of competent authority, the treaty process in the US, recent US tax treaty activities, treaty shopping, the USMCA Trade Agreement, and the future of tax treaties in the United States. Among the treaties and agreements discussed are US treaties and agreements with Chile, Croatia, Hungary, Taiwan, and Russia.

Moore v. US: Constitutionality of international tax

Wed, 20 Sep 2023 15:00:00 -0400

Doug McHoney (PwC's International Tax Services Global Leader) and Wade Sutton (former Deputy International Tax Counsel for the US Treasury and newly appointed ITS leader of PwC’s Washington National Tax Practice) are back in Washington, D.C. to discuss the recent Supreme Court grant of certiorari for the Moore v. US case. Doug and Wade go back to their law school days to break down the Moore case, starting with the facts, procedural history, and the potential implications if Section 965 is ruled unconstitutional, including direct taxation, indirect taxation, subpart F, Section 245A, GILTI, and, as always, Pillar Two.

Poutine Routine: Canada’s Pillar Two, DSTs, with G(AA)Ravy on top

Thu, 07 Sep 2023 09:00:00 -0400

Doug McHoney (PwC's International Tax Services Global Leader) and Ken Buttenham meet up in PwC’s Washington, D.C.. studio. Ken leads PwC Canada’s International Tax Practice from Toronto. Doug and Ken kick off with a discussion on Doug’s favorite Canadian food, then dive into the Canadian Pillar Two proposals, discussing the Global Minimum Tax Act (GMTA), UTPR, IIR, QDMTT, compliance, the GloBE Information Return, and tax incentives. They also cover digital services taxes (DSTs), the excessive interest and financing expenses limitation (EIFEL) rules, and the Canadian General Anti-Avoidance Rule (GAAR).

Pillar Two in Hong Kong SAR: Not yet a sticky wicket?

Tue, 22 Aug 2023 11:00:00 -0400

Doug McHoney (PwC's International Tax Services Global Leader) and Jesse Kavanaugh (PwC Hong Kong SAR’s Tax Reporting & Strategy Leader) met up at PwC’s AsiaPac Global Tax Symposium in Singapore. Jesse is an International Tax Partner in Hong Kong SAR and has been leading the region’s Pillar Two tax efforts. They discuss the state of play of Pillar Two in Hong Kong SAR, trends regarding safe harbours and data collection, modeling and calculations challenges, the centralized and decentralized approaches to Pillar Two inherent to the region, and the Hong Kong SAR legislative process. They also touch on the addition of Hong Kong SAR to the EU’s ‘grey list’ and the recent introduction of the Foreign Source Income Exemption (FSIE) Regime for Passive Income.

Pillar Two Administrative Guidance: More details, more questions

Mon, 14 Aug 2023 12:00:00 -0400

Doug McHoney (PwC's International Tax Services Global Leader) is back at Westminster Studios in St. Louis, Missouri where he’s joined by Steve Kohart, International Tax Principal with PwC in New York City and former Advisor for the Center for Tax Policy and Administration for the OECD. Together they discuss the latest wave of OECD Pillar Two guidance including the Subject-to-Tax-Rule (STTR), UTPR safe harbour, qualified domestic minimum top-up tax (QDMTT) safe harbour, marketable transferable tax credits (MTTCs), as well as the six key pieces of the substance base income exclusion (SBIE).

Pillar Two and Financial Services: What’s the deal?

Wed, 26 Jul 2023 11:00:00 -0400

Doug McHoney (PwC's International Tax Services Global Leader) is joined by first-time guest Winnie Tang, International Tax Partner in PwC’s Financial Services practice in New York. Doug and Winnie take a rapid fire tour of the Financial Services and Deals space in light of the Pillar Two Transition Period, touching on the definitions of funds, REITs, excluded entities, management company structures, POPEs, Pillar Two in the Deals space, and many more particularities taxpayers should be aware of.

Pillar Two in South Korea: Effective dates and much more

Wed, 12 Jul 2023 10:00:00 -0400

Doug McHoney (PwC's International Tax Services Global Leader) is at PwC’s AsiaPac Tax Symposium in Singapore. He is joined by Michael Kim, a PwC International Tax Partner and South Korea’s Outbound Tax Leader. Doug and Michael discuss South Korea’s enactment of Pillar Two, paying particular attention to effective dates, likely legislative actions, the incorporation of future guidance, how taxpayers are preparing for Pillar Two, Safe Harbours, data collection, and covered taxes.

EU’s Foreign Subsidies Regulation: State Aid goes global

Thu, 22 Jun 2023 11:00:00 -0400

Doug McHoney (PwC's International Tax Services Global Leader) is at PwC’s Global Financial Services Tax Leaders Meeting in Paris where he is joined by Will Morris, recently named PwC’s Global Tax Policy Leader. Together, they dive into the European Union’s Foreign Subsidies Regulation (FSR). They start with the origin story, how it intersects with State Aid, how taxpayers can be compliant, the necessity for collecting and saving data and information, consequences for failing to comply, and the challenges that taxpayers will face in the coming years, whether or not they currently do business in the European Union.

Sweet Child O'Mine: Inbounding Intangibles to the US

Wed, 07 Jun 2023 14:00:00 -0400

Doug McHoney (PwC's International Tax Services Global Leader) is joined by Aaron Junge, PwC National Tax Services International Tax Partner, and former Tax Counsel for the House of Representatives during the enactment of the Tax Cuts and Jobs Act. They discuss the historical perspective of the Section 367(d) rules beginning back in 1984, the recent regulations, and how we got here. Doug and Aaron touch on Section 367(d)’s original intended purpose, how the changes that occurred during TCJA changed intangible property (IP) ownership for US MNC’s (the carrot and the stick metaphor), the possible tax treatments of the repatriation of IP, the applicability dates, and how taxpayers can prepare, while considering Pillar Two, among other areas.

Freshly Served: Germany’s latest Pillar Two Draft

Wed, 24 May 2023 09:00:00 -0400

Doug McHoney (PwC's International Tax Services Global Leader) is joined in Madrid by Arne Schnitger, International Tax Partner with PwC Berlin and host of the German podcast Frisch Serviert (Freshly Served). They dive into the German legislative process, compliance and reporting, the German QDMTT, deviations from the OECD Model Rules, as well as the interaction with the US GILTI regime. They also discuss Arne’s recent article, “Does the 'Initial Phase Relief' Make the EU’s Pillar Two Directive Invalid?

Alphabet soup: A taste of EU tax

Tue, 09 May 2023 12:00:00 -0400

Doug McHoney (PwC's International Tax Services Global Leader) is joined in Madrid by Edwin Visser, PwC’s European Tax Policy Leader. Prior to joining PwC, Edwin was the Deputy Director General for Tax Customs Policy and Legislation and Director for Direct Taxes at the Dutch Ministry of Finance. One of the real challenges for tax professionals and advisors is the sheer volume of tax proposals from the European Union. Edwin and Doug discuss the numerous EU tax proposals, including the Carbon Border Adjustment Mechanism (CBAM), the Foreign Subsidies Regulation (FSR), Green Energy Credits, ATAD3. They also cover the EU’s legislative process, flashback to the Common Consolidated Corporate Tax Base (CCCTB), then tackle Business in Europe: Framework for Income Taxation (BEFIT), the SAFE project, and the Debt-equity bias reduction allowance (DEBRA). They cap the episode with a check in on Pillar One and Pillar Two.

Pillar Two: The UK’s latest installment

Thu, 27 Apr 2023 13:00:00 -0400

Doug McHoney (PwC's US International Tax Services Global Leader) hosts Matt Ryan, London-based International Tax Partner and leader of PwC’s UK Pillar Two Ready Team. Doug and Matt discuss the second draft of the UK’s Pillar Two legislation, the probable timing of enactment, the accounting implications, the UK’s Qualified Domestic Minimum Top-up-Tax, and some of the ‘deviations’ in the UK rules.

Threading the Needle: Pillar Two and the IRA’s Green Energy Credits

Wed, 19 Apr 2023 11:00:00 -0400

Doug McHoney (PwC's US International Tax Services Global Leader) is joined by Pat Brown, seven-time veteran of the podcast, and co-leader of PwC’s WNTS practice. Pat has previously worked in the private industry for 16 years, including several years as a VP of tax and director of tax policy. After Pat chooses his most and least favorite CBTT podcasts, Doug and Pat discuss green energy credits, the Pillar Two Model Rules and administrative guidance, how the US and UK R&D credits compare under Pillar Two, refundable credits, transferable credits, the equity investment inclusion election, and qualifying flow-through tax benefits.

Pillar Two: A Japanese perspective

Wed, 05 Apr 2023 10:00:00 -0400

Doug McHoney (PwC's US International Tax Services Global Leader) is joined by Shin Yamaguchi at PwC’s 2023 International Tax Conference. Shin is a Tokyo-based International Tax Partner, where he leads PwC Japan’s Inbound Tax Practice. Doug and Shin discuss Japan’s latest tax developments, focusing on the Pillar Two rules (of course!), specifically, UTPR, IIR, Safe Harbours, QDMTT, the GloBE Information Return and effective dates. They also discuss the Japanese legislative process.Since the recording of this podcast Japan has enacted their 2023 Tax Reform Bill which includes the Pillar Two Income Inclusion Rule which applies on or after April 1, 2024.

Disequilibrium: The new geopolitical and macroeconomic landscape

Tue, 28 Mar 2023 13:00:00 -0400

Doug McHoney (PwC's US International Tax Services Global Leader) is joined by Craig Stonberg at PwC’s 2023 International Tax Conference. Craig is PwC’s Macro Intelligence Leader, and spearheads a team of analysts helping global businesses with geopolitical risks, macroeconomic volatility, and supply chain shifts. Doug and Craig discuss the geopolitical landscape, particularly in Asia and Europe; how a recession would affect multinational companies, the labor shortage that is particularly affecting women, the geopolitical part of the energy equation, and how multinational companies should be preparing for 2023 and beyond.

Pillar Two Readiness: Complex data and complex challenges

Tue, 14 Mar 2023 18:00:00 -0400

Doug McHoney (PwC's US International Tax Services Global Leader) is back in Westminster Studios with Kate Miller, a Director in PwC’s Tax Reporting and Strategy Practice. Doug and Kate discuss what is meant by Pillar Two operational readiness and PwC’s Data Input Catalog, including the data requirements, the necessity of resources, the Data Input Catalog, safe harbours, ERP and enterprise systems, the importance of working as a team, how software tools can help, and the power of a centralized rules engine.

PwC’s Data Input Catalog

Searching for Pillar Two clarity: The OECD’s Administrative Guidance

Wed, 08 Mar 2023 11:00:00 -0500

Doug McHoney (PwC's US International Tax Services Global Leader) records from PwC’s 2023 International Tax Conference, where he is joined by Phil Ramstetter, PwC International Tax Partner based in Chicago. Phil was formerly a tax policy consultant for Business at OECD (BIAC). Doug and Phil overcome conference background noise to discuss the recent administrative guidance, but start with a history lesson on Pillar Two, when it was merely the Digital Project. Topics covered include blended CFC regimes, GILTI, expense apportionment, loss-making jurisdictions, transition period transactions, common control, the outlook for future guidance and some of the remaining open questions.

Pascal Saint-Amans: The Pillar Two Origin Story

Wed, 01 Mar 2023 11:00:00 -0500

Doug McHoney (PwC's US International Tax Services Global Leader) records from PwC’s 2023 International Tax Conference, where he is joined by Pascal Saint-Amans, former Director of the OECD's Centre for Tax Policy and Administration and current partner with Brunswick, a strategic advisory firm. Doug and Pascal dive directly into the BEPS Project with an overview of the Pillar Two origin story, the challenges and successes of the project, harmful tax practices and the ways the OECD is trying to change tax systems, the natural complexity of tax, the future of tax incentives, compliance requirements, the private sector’s role in the policy process and much more.

Opening a CAMT of worms? Notice 2023-7

Tue, 14 Feb 2023 12:00:00 -0500

Doug McHoney (PwC's US International Tax Services Global Leader) is joined by Jason Black, a PwC WNTS partner in the Federal Tax Services Group. Doug and Jason start with words of wisdom for accounting majors before diving into a discussion of the Corporate Alternative Minimum Tax (CAMT), formerly known as the Inflation Reduction Act’s Book Minimum Tax. They cover the details of Notice 2023-7, including the safe harbor rules, depreciation adjustments, M&A considerations, comparisons to Pillar Two, and much more.

Pillar Two: GloBE Return and CbyC Safe Harbours

Wed, 01 Feb 2023 14:00:00 -0500

Doug McHoney (PwC's US International Tax Services Global Leader) is joined by Mike Olecki, PwC’s International Tax Services Global Technology Leader and partner in the Quantitative Services Tax Practice. Doug and Mike discuss the OECD Pillar Two documents released in December 2022, including the transitional CbyCR safe harbour, the potential for a permanent safe harbour, the GloBE Information Return, calculation challenges, and how technology can help.

2022 Year in Review

Tue, 24 Jan 2023 09:00:00 -0500

Doug McHoney (PwC's US International Tax Services Global Leader) is joined by Pat Brown, International Tax Partner and co-Leader of the Washington National Tax Practice to look back at the very eventful and tortured 2022 year in international taxation. They cover topics including US Congressional activities, Treasury’s 2022 regulations and guidance, recent international tax and transfer pricing rulings, and the progress made on Pillar One & Two.

New FTC Regs: Raise your creditability score

Mon, 09 Jan 2023 10:00:00 -0500

Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Ninee Dewar, PwC International Tax Services Principal, to discuss the recently released 2022 proposed foreign tax credit (FTC) regulations. These regulations relax some of the stringent creditability requirements that were set forth in the 2021 final FTC regulations. Doug and Ninee dive into changes to the cost recovery requirement, the attribution requirement for withholding tax on royalty payments, and the definition of a reattribution asset for purposes of allocating and apportioning foreign taxes.

Propósito Principal: Mexican tax reforms

Mon, 19 Dec 2022 14:00:00 -0500

Doug McHoney, PwC’s International Tax Services Global Leader, is joined by Mario Alberto Gutierez, International Tax Partner based in Mexico City, and Leader of PwC’s International Tax Practice in Mexico. Doug and Mario discuss Mexico’s implementation of the multilateral instrument, Mexican tax treaties and the potential for treaty abuse, how the 2022 Tax Act changes the game with regard to share transfers, the Maquiladora regime, the Mexican manufacturing industry more broadly including business transformations and ‘near shoring,’ and debt structures and the ‘inflation adjustment’ in Mexico. Not surprisingly, Pillar Two makes a cameo appearance.

UK Updates: Pillar Two is Coming

Mon, 12 Dec 2022 11:00:00 -0500

Doug McHoney, PwC’s International Tax Services Global Leader, is in Barcelona, Spain at PwC’s Global Tax Symposium. On this episode, Doug is joined by Matt Ryan, a UK-based International Tax Partner with PwC. Doug and Matt discuss the UK’s parliamentary process, Liz Truss’s resignation, the corporate tax proposed changes, and Pillar Two, including a qualified domestic minimum tax, the income inclusion rule, and the under taxed payments rule. They also cover the finer points of UK’s treatment of asset transfers, deferred taxes, year-end adjustments, and the system and data requirements that companies must address.

Inbound Challenges: A Head of Tax Discussion

Mon, 28 Nov 2022 11:00:00 -0500

Doug McHoney, PwC’s International Tax Services Global Leader, is at PwC’s Global Transfer Pricing Conference in Berlin, Germany, joined by Omri Yaniv, Global Head of Tax at Amdocs Ltd, based in Tel Aviv. Omri is a former PwC partner, and the first Tax VP from a non-US-parented company to appear on the podcast. Doug and Omri discuss the three pillars of Omri’s job, Amdocs’ tax department, the accounting talent war, recent global tax changes, and the potential changes on the horizon.

Transfer Pricing: A macroeconomic view

Tue, 08 Nov 2022 12:00:00 -0500

Doug McHoney, PwC’s International Tax Services Global Leader, welcomes Horacio Pena, Tax Principal, Senior Economist and PwC’s Global Transfer Pricing Network Leader, to the podcast. Doug and Horacio provide the macroview of the transfer pricing environment, covering global inflation, China’s COVID restrictions, environmental volatility, the dollar’s strengthening against other currencies, regionalization, a brief touch on Pillar Two, country-by-country reporting, and more.

Pillar Two: A German Perspective

Wed, 26 Oct 2022 07:00:00 -0400

Doug McHoney, PwC’s Global International Tax Services Leader, is at PwC’s Global Transfer Pricing Conference in Berlin, Germany. Doug honors Ocktoberfest by donning lederhosenis to host Arne Schnitger, PwC International Tax Partner based in Berlin. Arne hosts the German tax podcast Frisch Serviert - der Steuerpodcast. They discuss Pillar Two issues in the EU, the US, and Germany, the differences approaches each jurisdiction takes when calculating the tax, the US book minimum tax, GILTI, refundable credits, allocation of expenses, the German implementation process, tax return filing, operational readiness, German anti-hybrid rules, and German Section 49.

Currency Exchange: Getting your Dollars worth

Mon, 10 Oct 2022 14:00:00 -0400

Doug McHoney (PwC's Global International Tax Services Leader) welcomes Rebecca Lee (Washington National Tax Services International Tax Partner). Doug and Rebecca discuss the many tax aspects of a strong US dollar, including cream skimming, foreign exchange gains and losses with branches and CFCs, previously taxed earnings, translational versus transactional gain or loss, and more. Can Doug and Rebecca go the entire podcast without mentioning a code section? Tune in to find out!

Reshaping US Transfer Pricing: Impact of Medtronic

Tue, 27 Sep 2022 14:00:00 -0400

Doug McHoney (PwC's Global International Tax Services Leader) welcomes first-time guest Kristina Novak (Washington National Tax Services Transfer Pricing Principal) and returning guest Alex Voloshko (PwC’s Value Chain Transformation Leader) to discuss the Medtronic case. They highlight the key takeaways including intellectual property considerations, transfer pricing trends, licensing models, business transformation trends for customers, and of course, a brief discussion of how Pillar Two will fit in.

The Metaverse and Tax: A non fungible discussion

Tue, 13 Sep 2022 12:00:00 -0400

Doug McHoney (PwC's Global International Tax Services Leader) welcomes Rebecca Lee, International Tax Services Principal in the Washington National Tax Practice for her sixth visit. Doug and Rebecca dispel myths associated with cryptocurrency and the metaverse. They break down definitions of some of the trickiest metaverse jargon, the tax implications of metaverse transactions, and where we are heading in the near future.

Let's make a Deal: What’s behind Pillar Two?

Tue, 30 Aug 2022 10:00:00 -0400

Doug McHoney (PwC's Global International Tax Services Leader) welcomes back podcast regular Calum Dewar (Principal, International tax services) to discuss Pillar Two. This time Doug and Calum dive deep into the deals area, including the Pillar Two tax consequences of specific deal transactions and structures. They also talk about the recent release of both the South Korea and UK Pillar Two draft rules.

The IRA and Book Minimum Tax: Not a Pillar Two Podcast

Wed, 17 Aug 2022 09:00:00 -0400

Doug McHoney (PwC's Global International Tax Services Leader) is joined by Aaron Junge in Westminster Studios. Aaron is International Tax Partner in PwC’s Washington’s National Tax Services and was previously Tax Counsel in the House Ways and Means Committee during the Tax Cuts and Jobs Act implementation. Doug and Aaron discuss the corporate alternative minimum tax (also called the ‘Book Minimum Tax’) and other Inflation Reduction Act tax provisions, which President Biden signed into law on August 16. More specifically, they cover the BMT effective date and its scope, what are applicable corporations, changes to the aggregation rules, what is applicable financial statement income, common adjustments, calculating the AMT foreign tax credit, and what guidance we might see from Treasury.

Risk modeling: Quantitative insights for business intelligence

Wed, 10 Aug 2022 10:00:00 -0400

Doug McHoney (PwC Global International Tax Services Leader) is joined by Richard de Haan, PwC Global and US Risk Modeling Services Leader. Doug and Rich discuss climate risk modeling, the climate for risk in the C-Suite, how ESG is impacting business decisions, data sources (including geospatial data) for modeling, dealing with risk in the supply chain,the impact of AI and machine learning, and how visualizations help tell the story.

Living with Uncertainty: Fortune 50 SVP of Tax and Treasury

Mon, 11 Jul 2022 11:00:00 -0400

Doug McHoney (PwC's Global International Tax Services Leader) is joined by Tadd Fowler, Senior Vice President, Treasurer and Head of Global Tax Operations of Procter and Gamble and former PwC International Tax Services partner. Doug and Tadd discuss Tadd’s perspective as a Treasurer and Head of Tax, P&G’s approach to tax, working with the C-suite, connecting with Global and US policymakers, advancements in technology, the new FTC rules, Pillar Two, and much more.

100th Episode Special: The evolution of global structuring

Wed, 22 Jun 2022 12:00:00 -0400

Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Mike Urse, current International Tax Partner and former US International Tax Services Leader for the 100th episode of the Cross Border Tax Talks podcast. Doug and Mike discuss the changing world of international taxation, focusing on the current status of holding companies, finance companies, and Intangible property companies. Mike provides insights and analysis from almost 40 years of international tax experience and sheds some light on the future state of play.

In the Clouds: Pillar 2 Operational Readiness

Mon, 13 Jun 2022 13:00:00 -0400

Doug McHoney (PwC's US International Tax Services Co-Leader) is joined in Washington D.C. by Dom Megna, Tax Partner and leader of PwC’s US Tax Reporting and Strategy practice. They discuss the latest on Pillar Two developments, GAAP considerations, Enterprise Resource Planning Systems, the Cloud, the future of data collection, and more.

Back to School: Mindy Herzfeld’s Pillar 2 insights

Wed, 25 May 2022 06:00:00 -0400

Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Mindy Herzfeld, professor of tax practice at the University of Florida Levin College of Law, where she teaches International Tax, to discuss Pillar Two rules.

Green Book Proposals: Codifying Pillar 2 in the US?

Mon, 09 May 2022 13:00:00 -0400

Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Pat Brown, PwC’s International Tax Policy Leader, making his sixth appearance on the podcast. Doug and Pat discuss the Biden Administration's fiscal year 2023 budget proposals as explained in the Green Book, how some of the proposals interact with the OECD’s Pillar Two Model Rules, and what taxpayers might expect.

Pillar 2 Commentary: A knowledge GAAP?

Wed, 27 Apr 2022 13:00:00 -0400

Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by PwC’s Calum Dewar, Leader of PwC’s Integrated Global Structuring practice. They discuss the Pillar Two Model Rules & Commentary and its potential impacts on the global tax system, transfer pricing adjustments, deals and more.

Spin the Globe Macroeconomic and Geopolitical trends

Wed, 06 Apr 2022 14:00:00 -0400

Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by PwC’s Dr. Alexis Crow, PwC’s Geopolitical Investing Practice Leader. They discuss macroeconomic trends, the geopolitical landscape, the inflationary environment, trade wars, global/economic impacts on various sectors,and much more.

The Final FTC Regs: Credibility for Creditability?

Thu, 24 Mar 2022 21:00:00 -0400

Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by PwC’s Washington National Tax Services International Tax Leader Michael DiFronzo, former Deputy Associate Chief Tax Counsel International at the IRS. They discuss some of the practicalities of the creditability rules in the Final FTC regulations (see February 2022 CBTT episode with Wade Sutton for an overview of the regulations), particularly cost recovery, attribution requirements, an unintended incentive to offshore IP, and foreign jurisdiction considerations.

Whirlpool Appellate Decision: A new standard for subpart F?

Wed, 09 Mar 2022 11:00:00 -0500

Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by PwC Value Chain Transformation Specialist Tom Quinn. They discuss the Sixth Circuit Court of Appeals ruling to uphold the US Tax Court’s May 5, 2020 decision, and concluded that a CFC’s income ‘attributable to’ a branch, in this case a manufacturing branch, per se is foreign based company sales income (FBCSI) under the statute if a ‘substantial tax deferral effect’ is found. They specifically discuss the Maquilladora structure, FBCSI, a ‘substantial tax-deferral effect’, the Court’s interpretation of the branch rule, and future implications for other taxpayers.

Note: Since the recording of this podcast, the US Court of Appeals for the Sixth Circuit denied Whirlpool’s request for a rehearing. Whirlpool has 90 days from March 2, 2022, to petition for certiorari with the US Supreme Court.

ATAD3 - impacting the financial services industry and more

Wed, 23 Feb 2022 22:00:00 -0500

Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Puneet Arora, PwC ITS Partner and PwC’s Financial Services Consulting leader. They discuss the latest EU anti-tax avoidance directive (ATAD3), diving into the details and impact it could have on the financial services industry; the importance of modeling for Pillar Two; and the G in ESG, governance.

Double taxation ahead? Parsing the final FTC regs

Mon, 07 Feb 2022 14:00:00 -0500

Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Wade Sutton, PwC ITS Partner in the Washington National Tax Practice office and former deputy international tax council at Treasury. They discuss the highly technical topics of the final foreign tax credit regulations, credibility of tax under Section 901, the definition of an income tax, DSTs, nonresident taxation, effective dates, digital services taxes, withholding taxes, nonresident capital gains taxes, Puerto Rican excise tax, BEPS 2.0 and much more.

All aboard! The Pillar Two train is leaving the OECD and EU stations

Fri, 21 Jan 2022 14:00:00 -0500

Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Calum Dewar, PwC ITS Partner and leader of PwC’s Integrated Global Structuring Practice, heading our Outbound, Inbound, and Value Chain Transformation teams. Doug and Calum discuss Pillar Two Model Rules, the OECD/G20’s Inclusive Framework, the EU Directive, and more specifically the Income Inclusion Rule, the Under Tax Payment Rule and how country-by-country GILTI and the new final FTC regulations could impact the result for US MNCs.

Below the line: Getting tax a seat at the business table

Wed, 05 Jan 2022 21:00:00 -0500

Doug McHoney (PwC's US International Tax Services Co-Leader) is joined in PwC’s DC studio by Mohamed Kande, PwC Vice-Chair and US and Global Advisory Leader. They discuss the need for proactive and intentional mentorship; relationship building in the virtual environment; the three different types of transformation trending in the market; and how (and why) tax should get a seat at the business table.

Tax reform: Digging in, before building back

Tue, 14 Dec 2021 09:00:00 -0500

Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Jeff Endress, US Outbound Tax Practice leader. They discuss the House-passed Build Back Better (BBB) bill, delayed effective dates, Section 163(n), foreign tax credits, country-by-country, the complexity of global tax, Pillar Two, uncertainties in the deals market, and the future of tax reform.

Why International Tax? One professional's career journey

Tue, 30 Nov 2021 14:00:00 -0500

Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Ugo Alisiobi, ITS Partner, based in our New York Metro ITS practice, for Ugo’s first time in St. Louis. They discuss their paths to careers in international taxation; the struggles, joys, and rewards of being an international tax practitioner; being proactive and authentic in your career; imposter syndrome; finding - and being - a mentor; and working at PwC.

Cryptocurrency Trends: Blockchain goes mainstream

Wed, 10 Nov 2021 14:00:00 -0500

Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Rebecca Lee (PwC ITS Washington National Tax Partner), who specializes in cross-border financial transactions. They discuss trends in cryptocurrency, including ‘operation hidden treasure,’ taxation of cryptocurrency transactions, US tax reform, El Salvador’s adoption of Bitcoin as legal tender, blockchain in the insurance industry, Bitcoin as an exchange traded fund (ETF), the digitalization of trust, updates on non fungible tokens (NFTs), the impact of decentralized finance (DeFi) on capital markets, and market implications around the world.

BEPS 2.0 Update: not IF but when

Tue, 26 Oct 2021 10:00:00 -0400

Doug McHoney (PwC's US International Tax Services Co-Leader) is in PwC's brand new studio in Washington, DC with Will Morris (PwC’s Deputy Global Tax Policy Leader). Will also was appointed Chair to the American Chamber of Commerce to the European Union and Chair to the Business Industry Advisory Committee to the OECD. Doug and Will discuss the journey thus far to Pillar One and Pillar Two. They touch on, among other things, the future impacts on US-based multinational companies, what has changed in recent months, digital services taxes & unilateral measures, details of Amount A under Pillar One, possible winners and losers, segmentation, scoping, the potential new instrument needed for implementation, details of Globe under Pillar Two, including the minimum rate, and of course, the timeline for implementing these changes.

Playing by House Rules: More analysis of the Ways & Means bil

Fri, 08 Oct 2021 11:00:00 -0400

Doug McHoney (PwC's US International Tax Services Co-Leader) is back in Westminster Studios with Nita Asher (PwC International Tax Services Partner), who served as legislative council at the Joint Committee on Taxation from 2017 to 2018. Doug and Nita pick up from the previous podcast with Sherry Grabow, and discuss the legislative climate; covering, among other topics: the legislative process for tax reform, how this iteration of reform differs from 2017, granting of regulatory authority, impact of proposed changes to Section 163(n), the wholesale changes proposed to BEAT; clarification to foreign personal holding company income; and new foreign tax carryforward rules.

Tax Reform 2.0: the House "Ways" in

Mon, 20 Sep 2021 13:00:00 -0400

Doug McHoney (PwC's US International Tax Services Co-Leader) is live at the Westminster Studios with Sherry Grabow (PwC's US International Tax Services Co-Leader) to discuss the international tax provisions in the recently released ‘Chairman’s Mark’ from the House Ways and Means Committee. Doug and Sherry cover, among other topics: Interest expense under new Section 163(n) and existing Section 163(j); changes to foreign derived intangible income (FDII), modifications to the global intangible low-taxed income (GILTI) regime, changes to the foreign tax credit rules; sweeping changes to subpart F income; a refreshed base erosion and anti-abuse tax (BEAT), and how taxpayers should prepare for potential changes to the tax rules.

Tax Reform 2.0: Hot topics in inbound taxation

Wed, 01 Sep 2021 12:00:00 -0400

Doug McHoney (PwC's US International Tax Services (ITS) Leader) is live at the Westminster Studios with Tom Patten (ITS Partner based in London) to discuss current and future tax considerations for US inbound companies. Doug and Tom chew on toasted ravioli and sandwich structures and then cover, among other topics: the impact of a Pillar 2 regime on US inbound companies; the potential for replacing the base erosion anti-abuse tax (BEAT) with the Stopping Harmful Inversions and Ending Low-tax Developments (SHIELD) provision, impending changes and proposals to interest expense, further limiting the ability of domestic corporations to expatriate; the effects of Brexit on US inbounds; and the potential for Pillar 1 to spurn treaty negotiation and ratification.

A hundred year storm: BEPS 2.0 Update

Fri, 20 Aug 2021 14:00:00 -0400

Doug McHoney (PwC's US International Tax Services Leader) is live at the Westminster Studios with Calum Dewar (Integrated Global Structuring Leader) to discuss the OECD’s Two Pillar solution to address the taxation of the digitalization of the economy. Doug and Calum cover, among other topics: Pillar 1 - the reallocation of profits of large multinational companies; Pillar 2 - a global minimum tax rate of at least 15%; the momentum to find a consensus agreement; the design challenges the OECD still faces; how PIllar 2 proposals compare to the US GILTI regime; the potential for carve outs and segmentation; the implementation obstacles in the United States; and the importance of US multinationals to engage with policy makers.

Bringing code to the Code: Tech trends in International Tax

Wed, 04 Aug 2021 11:00:00 -0400

Doug McHoney (PwC's US International Tax Services Leader) is live at the Westminster Studios with John McDonald (Quantitative Solutions & Technologies Managing Director) to discuss the role of technology in tax. Doug and John cover, among other topics: the cross section of computer science and tax; the economics of the professional services industry; how TCJA has made taxation much more complex; the digital evolution of tax research; the power of definitions and testing to retain information; the usefulness of a graph data structure in tax; how centralized rules engines are superior to spreadsheets; the power of visualizations; the future of probability analysis in taxation, and the need for change management.

EU Update: State Aid, CBCR and Tax in the 21st Century

Wed, 21 Jul 2021 09:00:00 -0400

Doug McHoney (PwC's US International Tax Services (ITS) Leader) holds another post-vaccine session live at the Westminster Studios with Maarten Maaskant (PwC’s Foreign Tax Desk Leader) to discuss the latest happenings in the European Union (EU) from a legislative, administrative, and judicial perspective. Doug and Maarten cover, among other topics: both the Amazon and Engie state aid decisions in the EU General Court and their future implications; public country-by-country reporting; the European Commission (EC) proposal for a new instrument to address potential distortive effects of foreign subsidies; and the EC communication on business taxation for the 21st century.

Post Covid-19 globalization: Dead, dying, or here to stay?

Thu, 01 Jul 2021 11:00:00 -0400

Doug McHoney (PwC's US International Tax Services (ITS) Leader) sits down virtually with Dr. Alexis Crow (PwC's Global Leader of Geopolitical Investing Practice) to discuss the state of globalization, and more specifically, whether we have seen the end of globalization. Doug and Alexis cover how the landscape has shifted, and how we got to the current state; tensions within the technology sector, including a 'cold war' from a technology perspective; the globalization of the financial services sector; possible solutions for global cohesion; trends in tax and business from digital and environmental perspectives, and the increasing significance of Asia's role; climate policies and the 'greening' of financial flows; and the future of globalization, including what business leaders and investors should expect in a covid-recovering global economy.

Explaining the explanation: Biden’s Greenbook

Tue, 08 Jun 2021 12:00:00 -0400

Doug McHoney (PwC's US International Tax Services (ITS) Leader) holds the second post-vaccine session live at the Westminster Studios with Pat Brown (PwC WNTS Policy Co-leader) to discuss President Biden’s FY 22 Budget and the much anticipated and related explanations of such proposals, also known as the Treasury Green Book. Doug and Pat cover, among other proposals: increasing the US corporate income tax rate from 21% to 28%; increasing the global intangible low-taxed income (GILTI) tax rate to 21%; removing the qualified business asset investment (QBAI) provision; repealing the deduction for foreign derived intangible income (FDII); replacing the Base Erosion and Anti-Abuse Tax (BEAT) with a Stopping Harmful Inversions and Ending Low-tax Developments (SHIELD) provision; restricting deductions of excessive interest for disproportionate borrowing in the US; the status and likelihood of the OECD’s Pillars One and Two; and what companies should consider as potential tax legislation becomes more likely.

Environmental, social & governance (ESG): Taxing matters

Tue, 25 May 2021 20:00:00 -0400

Doug McHoney (PwC's US International Tax Services (ITS) Leader) is joined in person at the Westminster Studios by David Parrish (PwC's ESG Tax Leader) to discuss the umbrella term environmental, social, & governance. Doug and David cover: the definition of ESG; its effects on a company's business and footprint; the driving forces of NGOs, investors, consumers, and governments; the impacts it has on deals, capital investment, & tax; the alignment of ESG corporate strategies and goals; and the path forward from sustainability, transparency, and value chain perspectives.

Acción Inmediata: Mexico adopts labor subcontracting rules

Tue, 11 May 2021 15:00:00 -0400

Doug McHoney (PwC's US International Tax Services Leader) and David Cueller (PwC Mexico’s Tax and Legal Services Leader) discuss Mexican developments, including outsourcing reform and Mexico's current position in the OECD BEPS Project. Doug and David cover: the history of Mexico's outsourcing regime; recent disruptive changes made to various laws, including the Income Tax Law, VAT Law, and Labor Law; the specialized services exception; companies impacted by the recent law changes; the potential for penalties and tax fraud; relevant compliance concerns; and US tax considerations. They also discuss Mexico's BEPS-aligned legislation and the non-deductibility of payments to certain foreign entities.

Behind the scenes: a tax policy discussion with Chip Harter

Wed, 05 May 2021 16:00:00 -0400

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Chip Harter (Senior Policy Advisor in PwC's Washington National Tax Services Practice and former Deputy Assistant Secretary for International Tax Affairs in the Office of Tax Policy at the US Department of the Treasury) discuss Chip's experiences at Treasury and the latest outlook for tax policy. Doug and Chip cover: Chip's involvement in the review and publication of IRS regulations and the role of Treasury officials in the regulations' process; Chip's involvement in the Tax Cuts and Jobs Act (TCJA); Chip's thoughts on the global intangible low-taxed income (GILTI) regime and his reaction to the interplay of the foreign tax credit regime and GILTI; the history and recent updates to the GILTI high-tax exception; and the prospects for a 'true' global minimum tax and the outlook for agreement on the OECD's base erosion and profit shifting (BEPS) project.

SPACs: the confluence of A-list celebs and Sec. 7874

Wed, 14 Apr 2021 00:00:00 -0400

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Thomas Groenen (PwC's US ITS-Financial Services Leader) discuss the renewed interest in special purpose acquisition companies (SPACs). Doug and Thomas cover: how Thomas made his way from the UK to the US; Thomas's advice for individuals interested in moving to the United States to become tax professionals; what a SPAC is and how it generally functions; the history of SPACs—dating back to the British 'South Sea bubble' in the early 18th century; how SPACs compare to and interrelate with IPOs; how and why individuals and entities invest in SPACs; the tax implications for SPAC investors; considerations regarding the SPAC's jurisdiction; the SPAC lifecycle, from founding to de-SPACing; the importance of choosing the correct investment vehicle (both corporate v. pass-through and domestic v. foreign); how the passive foreign investment company (PFIC) regime interplays with foreign SPACs; and the possible future of SPACs.

From Audit to Tax: a conversation with PwC’s US Tax Leader

Thu, 01 Apr 2021 12:00:00 -0400

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Kathryn Kaminsky (PwC's Vice Chair - US Tax Leader) discuss Kathryn's background and her transition to PwC's US Tax Leader. Doug and Kathryn cover: Kathryn's experience as a woman in the audit and tax professions; how men can be advocates and allies for women; the differences between advocacy and mentorship; how to ensure career paths are not inhibited by the desire to have a family; Kathryn's experience as an auditor and leading practices for tax practitioners, auditors, and businesses; the challenges in communicating nuanced technical issues; challenges in transitioning from Audit to Tax and what we can learn from Kathryn's experiences over the past nine months as US Tax Leader; best practices for remote working; conversations Kathryn has been having with companies regarding potential upcoming domestic and global tax policy changes; how tax professionals can elevate issues to the C-suite; and why every business decision has a tax implication.

Social justice: how the CEO Action for Racial Equity is effectuating change

Thu, 18 Mar 2021 22:00:00 -0400

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Roy Weathers (PwC's Vice Chair for Societal Engagement and Policy Solutions) discuss Roy's new role as CEO of CEO Action for Racial Equity. Doug and Roy cover: what CEO Action for Racial Equity is and its goals; the resources businesses like PwC and other companies have committed; how CEO Action for Racial Equity is effectuating policy change to advance racial equity; how data and technology help CEO Action for Racial Equity fellows ideate policies and ideas; how the fellows analyze and prioritize issues; specific issues that CEO Action for Racial Equity is targeting, such as telehealth; potential politicization over these types of issues and how data and common interests can help overcome the politicization; Roy's experience as a Black tax professional; and how everyone can keep the momentum going to implement, cause, and create change.

Trading places: Trade considerations for tax professionals

Thu, 04 Mar 2021 00:00:00 -0500

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Chris Desmond (PwC's Global Trade Services Practice Leader) discuss the global trade landscape. In addition to their prognostications for Major League Baseball's NL Central division, Doug and Chris cover: how trade and tax are interrelated; how businesses can structure their trade and tax groups to encourage coordination; the 'big picture' trade landscape both inside and outside of the US; recent changes to US trade regulations; Section 301 and how Section 301 tariffs operate; impacts that Katherine Tai—President Biden's nominee for United States Trade Representative—may have on US trade policy; what duty drawback is and how businesses can utilize it; global updates to digital service taxes (DSTs) and how Section 301 tariffs interrelate with DSTs; how practical it is for businesses to shift supply chains in light of tariffs; President Biden's 'Made in America' executive order and how it may impact multinational enterprises; the importance of modeling from both a trade and tax perspective; and final pieces of advice for taxpayers.

Grab your passport: global tax policy update

Thu, 18 Feb 2021 09:00:00 -0500

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Will Morris (PwC's Deputy Global Tax Policy Leader) discuss important updates to international tax policy. Doug and Will cover: recent updates to the OECD's base erosion and profit shifting (BEPS) project—BEPS 2.0—including the proposed timeline for agreement, unresolved issues in the Pillar One and Pillar Two Blueprints, and potential challenges to implementation; recent IRS and Treasury appointees and how these individuals may affect domestic and international policy; the challenges of amending US treaties even if the OECD's Inclusive Framework reaches consensus; the EU Court of Justice's recent decision in Lexel AB v. Skatteverket regarding the EU's 'freedom of establishment' concept and how this decision may cause challenges in implementing Pillar Two in the European Union; recent developments concerning digital service taxes (DST), including a look at the UK's proposed online sales tax and diverted profits tax, India's equalization levy, and Indonesia's electronic transactions tax; a recent court decision in France related to a permanent establishments; and how taxpayers can prepare for international tax disruption.

More items of interest: The final 163(j) regulations

Thu, 11 Feb 2021 10:00:00 -0500

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Rebecca Lee (ITS Partner in PwC's Washington National Tax Services office) have much to cover with the recently released final regulations under Section 163(j). Doug and Rebecca discuss: the background of the interest expense limitation rules under Section 163(j); the content and formulation of the 2018 proposed regulations, 2020 proposed regulations, and 2020 final regulations issued under Section 163(j); the new administration's potential influence on the 2021 final regulations; how the 2021 final regulations amend the definition of 'interest' and the calculation of adjusted taxable income (ATI); how the 2021 final regulations affect C corporations, consolidated groups, and partnerships; what the CFC group election is and how companies can make the election; the many anti-abuse rules contained in the 2021 final regulations; changes to the safe-harbor election; and advice for taxpayers on how to consistently and accurately apply the multitude of rules under Section 163(j).

Bring SALT to the table: Key state and local topics

Fri, 05 Feb 2021 06:00:00 -0500

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Rob Ozmun (State and Local Tax (SALT) Partner in PwC's Washington National Tax Services office) peel the onion on how state and local tax issues can impact cross-border planning, and vice versa. Doug and Rob set the table with a brief primer on state and local corporate tax, then devour topics including: state conformity to the Internal Revenue Code; how different states have handled federal developments regarding subpart F income, global intangible low-taxed income (GILTI), the Section 965 'toll charge,' and the Section 250 deduction; how businesses are analyzing the dividends received deduction (DRD) under Section 245A and the GILTI high-tax exception at the state level; important state and local considerations related to the business interest expense deduction rules under Section 163(j); how states have reacted to the CARES Act; how states have implemented (or declined to implement) the base-erosion and anti-abuse tax (BEAT); and key considerations for taxpayers. Come hungry for knowledge, leave satiated.

US tax reform 2.0? Biden's international tax campaign proposals

Fri, 22 Jan 2021 17:00:00 -0500

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Nita Asher (ITS Partner in PwC's Washington National Tax Services office) cover some of President Biden's campaign tax proposals. Doug and Nita discuss: the current state of Congress and the White House; President Biden's campaign proposals to increase the corporate and global intangible low-taxed income (GILTI) tax rates, move the GILTI determination to a country-by-country basis, eliminate the exemption for qualified business asset investment (QBAI), amend the base erosion and anti-abuse (BEAT) tax, and implement a minimum tax on global book income; how President Biden's proposals interact with the OECD's ongoing base erosion and profit shifting (BEPS) project; the budget reconciliation process in the Senate and the likelihood of Congress enacting President Biden's proposals; what the regulatory landscape may look like under the Biden administration; and why taxpayers should engage with policymakers in a timely manner.

Supply and demand: key value chain considerations in 2021

Wed, 06 Jan 2021 20:00:00 -0500

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Alex Voloshko (PwC's Value Chain Transformation Leader and ITS Partner in PwC's Washington National Tax Services office) discuss key considerations for value chains in 2021. Doug and Alex define 'value chain,' and how it includes the 'supply chain,' the 'demand chain,' and more; how value chains impact tax and transfer pricing; how supply chains were disrupted in 2020 and the outlook for supply chains in the new year; the plethora of factors that go into value and supply chain planning, including cost structure, access to qualified labor and production capabilities, regulatory considerations, and tax costs; the growing pressure on companies to 'near shore' and diversify their value chains; important trends for multinational entities, including increased scrutiny from tax authorities and increased transparency; the increasing importance of managing growth in a strategic manner; and recent trends concerning permanent establishments (PE).

WHT do you mean? A 95 year old German withholding tax on royalties

Thu, 10 Dec 2020 12:00:00 -0500

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Dr. Arne Schnitger (Head of PwC Germany's National Tax Office) discuss withholding taxation in Germany pursuant to Section 49 of Germany's tax code. Doug and Arne discuss: the background of Germany's Section 49 withholding tax and the circumstances under which Section 49 applies; the recent Circular issued by the German authorities discussing the application of Section 49; potential legal challenges to Section 49 taxation, including constitutionality and estoppel; the definition of 'German-registered IP' and 'EU-registered IP', and how tax advisers determine which royalties are subject to tax under Section 49; the interplay between withholding taxation and treaty jurisdictions; the importance of exemption certificates for prospective payments; what companies should do regarding historic liabilities; potential penalties for failure to file and/or remit tax as required by Section 49; and final pieces of advice for multinational taxpayers impacted by Section 49. [NOTE: The majority of this episode was recorded prior to the German Ministry of Finance's release of draft, proposed legislation (in German) regarding the effective repeal of Section 49(1) on an extraterritorial basis as it applies to IP registered in Germany. During the final five minutes of this podcast, Doug and Arne discuss key takeaways from this draft legislation.]

Extension cord: The story of tax extenders

Mon, 30 Nov 2020 12:00:00 -0500

Doug McHoney (PwC's US International Tax Services Leader) and Rohit Kumar (co-leader of PwC's Washington National Tax Services practice) discuss the past, present, and future of tax extenders. Doug and Rohit discuss: Rohit's experience as Domestic Policy Director and Deputy Chief of Staff for Senate Majority Leader Mitch McConnell; what tax extenders are and why they exist; the importance of the ten-year congressional budget window; the political calculus involved in determining whether certain tax provisions are temporary or permanent; the background and history of the controlled foreign corporation (CFC) look-through rule; potential alternatives to the tax extender regime; and the necessity for bipartisanship due to the upcoming 'fiscal cliff' at the end of 2025, caused by the potential expiration of a multitude of Tax Cuts and Jobs Act (TJCA) provisions.

Going for the gold: macroeconomics in 2021 and beyond

Fri, 13 Nov 2020 16:00:00 -0500

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Craig Stronberg (leader of Macro Capability for PwC Intelligence) discuss key macroeconomic considerations after November's elections. Doug and Craig discuss: the global implications of President-elect Biden's upcoming administration; the potential for tax reform in 2021 and beyond; the future of trade and diplomacy with China, including potential changes to supply chains, onshoring, and digital currencies; trends in 'protectionism' both inside and outside the US; key advice Craig has for executives and multinational corporations in light of the current geopolitical uncertainties; and Craig's experience working to protect the Olympic games.

Hard hat area: the OECD's Blueprints on Pillar One and Pillar Two

Fri, 30 Oct 2020 17:00:00 -0400

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Pat Brown (PwC's International Tax Policy Leader) discuss the OECD's recently released blueprints on Pillars One and Two. Doug and Pat discuss: Pat becoming the most frequent Cross-border Tax Talks guest (four) and the sizing for Pat's 'Five-Timers' jacket when he next appears (spoiler: 42 Long); the background of the OECD's base erosion and profit shifting (BEPS) project and the progression from 'BEPS 1.0' to 'BEPS 2.0'; the background of Pillar One, including a discussion of 'Amount A' and 'Amount B'; the background of Pillar Two, including a discussion of the 'undertaxed payments rule' and the 'income inclusion rule'; highlights from the OECD's Blueprint on Pillar One, including the concept of 'consumer-facing businesses'; highlights from the OECD's Blueprint on Pillar Two, including the OECD's 'jurisdictional-blending' approach and the 'income-inclusion' regime; and what the future looks like for BEPS 2.0 implementation in 2021 and beyond.

You down with FTC? The new Foreign Tax Credit regulations

Fri, 23 Oct 2020 14:00:00 -0400

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Mike Urse (ITS Partner in PwC's Washington National Tax Services practice) discuss the recently released final and proposed foreign tax credit (FTC) regulations. Doug and Mike (who participated in our inaugural CBTT podcast over two years ago) go deep on interest, stewardship, and research and development (R&D) expense apportionment under the final FTC regulations; the importance in modeling potential retroactivity of the R&D regulations; the intricacies in allocating and apportioning foreign taxes; foreign tax redeterminations under Section 905(c); the 'disregarded payment rule' under the proposed regulations; how to determine if a tax is 'creditable' and the new concept of 'jurisdictional nexus' in the proposed regulations; the revocation of the 'contested tax doctrine,' and additional proposed changes to the research and expenditure (R&E) allocation rules. Mike leaves listeners with a nice summary of the highlights and key takeaways from these regulations.

Tales from the crypt(o) - Global taxation of digital assets

Fri, 16 Oct 2020 17:00:00 -0400

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Mazhar Wani (PwC's FinTech Tax Leader) discuss PwC's Annual Global Crypto Tax Report and recent developments concerning digital assets. Doug and Mazhar discuss: what 'digital assets' are; the OECD's recent report, 'Taxing Virtual Currencies,' and how it compares with PwC's Annual Global Crypto Tax Report; the distinctions between cryptocurrencies and digital assets; the increase in guidance concerning digital assets and potential incentives for jurisdictions to lead in the digital asset space; how regulators around the world are treating the taxation of digital assets; the importance of classifying digital assets as 'property' or 'currency,' and distinctions between the two classifications; what 'staking' is and recent global trends regarding 'staking'; what 'decentralized finance' (DeFi) is and the future of DeFi; trends in the indirect tax space concerning digital assets; and recommendations for taxpayers looking to enter the digital asset space.

Extraordinary Considerations: the 245A DRD regulations

Fri, 02 Oct 2020 14:00:00 -0400

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Aaron Junge (ITS Partner in PwC's Washington National Tax Services practice) discuss the recently-released final and proposed dividends received deduction (DRD) regulations under Section 245A. Doug and Aaron discuss: Aaron's background as Tax Counsel for the Committee on Ways and Means in the US House of Representatives and how this experience proves valuable in the private sector; the background and architecture of Section 245A; important topics included in the final and proposed DRD regulations including hybrid dividends, extraordinary dispositions (ED), and extraordinary reductions (ER); topics not fully contemplated in the final and proposed regulations, including certain mechanical rules of the DRD; how the ED rules interplay with the global intangible low-taxed income (GILTI) and Section 965 'toll charge' rules; notable changes from the 2019 temporary DRD regulations to the 2020 final DRD regulations, including changes to the treatment of sales of intellectual property (IP) and mitigating the circumstances in which the DRD rules produce double-taxation; what an ER is and how the final regulations clarify the year-end close election; and major takeaways from the proposed regulations, including coordination of the ED rules and application of the disqualified basis rules.

Road to Election 2020 with Chairman Dave Camp

Fri, 18 Sep 2020 07:00:00 -0400

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Chairman Dave Camp (Senior Policy Advisor in PwC's Washington National Tax Services practice and former Chairman of the House Committee on Ways and Means) discuss the past, present, and future of tax policy. Doug and Chairman Camp discuss: Chairman Camp's proposals for a global minimum tax during his tenure in Congress and how his proposals compare to the OECD's Base Erosion and Profit Shifting (BEPS) project; Vice President Biden's tax proposals, including amending the corporate tax rate, imposing a tax on book income, eliminating tax preferences for certain industries, and doubling the tax rate for global intangible low-taxed income (GILTI); the roles that the Senate, the US economy, and the global economy play in potential tax reform; President Trump's tax proposals; the evolution of the 'party platform,' political parties, and political factions; similarities and differences between the American political system and parliamentary systems; and the impact and utility of social media in the political sphere. [NOTE: This episode was recorded prior to the release of the "The Biden-Harris Plan to Fight for Workers" fact sheet released on September 9 by the Biden-Harris campaign.]

GILTI as charged (3rd booking): the 2020 high-tax exception regs

Fri, 11 Sep 2020 12:00:00 -0400

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Elizabeth Nelson (ITS Partner in PwC's Washington National Tax Services) discuss the recently-issued final and proposed high-tax exception regulations under the global intangible low-taxed income (GILTI) and subpart F income regimes. Doug and Elizabeth unpack: the background and history of the high-tax exception; the similarities and differences between the previously proposed high-tax exception regulations and the final high-tax exception regulations; how the regulations interact with net operating losses (NOLs) and the base erosion and anti-abuse tax (BEAT); what happened to QBUs, what is a 'tested unit,' and how the aggregation rules apply to tested units; the substance and implications of the 'consistency rule,' how the proposed regulations treat expense apportionment and negative interest rates; the new documentation requirements and anti-abuse rules contained in the regulations; and the continued importance of modeling due to the high-tax exception's interaction with many other TCJA provisions. Doug and Elizabeth also 'put a fork' in the notion that GILTI is a minimum tax and identify three categories of multinational taxpayers that may want to elect the high-tax exception.

Items of interest: The 163(j) Regulations

Thu, 27 Aug 2020 13:00:00 -0400

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Rebecca Lee (ITS Partner in Washington National Tax Services) discuss the recently-issued Section 163(j) final and proposed regulations. Doug and Rebecca discuss: what Section 163(j) is and how the Tax Cuts and Jobs Act changed the interest expense limitation rules for corporations; effective dates for both the final and proposed regulations; how the final regulations define 'interest;' the breadth of the anti-avoidance rule in the final regulations; how the final regulations define 'adjusted taxable income' and 'tentative taxable income;' how the final regulations treat the separate return limitation year (SRLY) limitation; and major takeaways of the proposed regulations, including how the proposed regulations treat controlled foreign corporations (CFCs), foreign persons with effectively-connected income (ECI), and partnerships.

Second bite of the Apple: the EU State Aid decision

Mon, 17 Aug 2020 22:00:00 -0400

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Calum Dewar (a Partner in PwC's Washington National Tax Services (WNTS) ITS practice and leader of PwC's US Integrated Global Structuring practice) discuss the recently-issued Apple State Aid opinion from the General Court of the European Union. Doug and Calum discuss: what State Aid is; what the General Court's opinion says and how to interpret it; the procedure behind the European Commission's initial 2016 decision, including why Apple was not actually the defendant in the initial case, but why both the Irish government and Apple appealed the EC's decision to the General Court; the impact of US cost-sharing rules and transfer pricing methodologies on the General Court's decision; the role of 'selectivity' in State Aid; how the EC may act in this case, and in other State Aid cases, going forward; and what impact digital services taxes and the OECD's base erosion and profit shifting (BEPS) project may have on State Aid in the future.

FDII shades clearer: the final Section 250 regulations

Thu, 30 Jul 2020 23:00:00 -0400

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Ninee Dewar (a Partner in PwC's Washington National Tax Services (WNTS) ITS practice) discuss the recently-released Foreign Derived Intangible Income (FDII) final regulations under Section 250. Doug and Ninee discuss: the background of the Section 250 deduction and how the deduction interplays with both FDII and Global Intangible Low-Taxed Income (GILTI); how the final regulations compare to the March 2019 proposed regulations under Section 250, including various changes to the documentation rules and loss transactions; Ninee's advice for taxpayers to meet the substantiation requirement; the background of the 'ordering rule' and how the rule helps coordinate Sections 250, 163(j), and 172(a); the importance of remembering that the Section 250 deduction is a taxable-income deduction (particularly in light of recent changes to the Net Operating Loss rules); how the final regulations treat electronically-supplied services and advertising services; how the final regulations treat related-party sales; and various important effective dates and applicability dates for the final and proposed regulations.

The evolution of 'cut and paste': 40 years of tax policy

Fri, 17 Jul 2020 14:00:00 -0400

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Pam Olson (PwC's US Deputy Tax Leader and Washington National Tax Services (WNTS) Practice Leader) discuss Pam's storied career as she retires from PwC. Doug and Pam talk: life as a tax practitioner in the 1980s; the value in working for the government; Pam's top achievements during her tenure at Treasury; major trends in US and global tax policy; the growth of trade, investment, supply chains, and globalization; the progressivity of the US tax system; the increase in partisanship over the past 40 years and the melding of 'campaigning' and 'governing' over that time; how we can focus on what we have in common rather than focusing on our differences; the recycling of tax proposals; and Pam's advice for both US and global policymakers.

A conversation about race in the tax profession

Thu, 25 Jun 2020 18:00:00 -0400

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Stephen Mosha (an ITS Partner and leader of PwC's Northeast Tax practice) have a candid conversation about Stephen's life as a Black tax professional. Doug and Stephen discuss: Stephen's experience as a Black partner at PwC; Stephen's thoughts on the homogeneity of the tax profession, how Stephen became interested in international tax; how tax professionals can help address racial inequities; and Stephen's advice for Black international tax professionals.

DAC6 Update: the latest EU disclosure rules

Fri, 12 Jun 2020 13:00:00 -0400

Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Maarten Maaskant (an ITS Partner and ITS Desk Leader) discuss the EU's mandatory reporting rules (EU Council Directive 2018/822, also known as 'DAC6.') Doug and Maarten cover: the background of DAC6 and how it compares to the BEPS Action Item 12 concerning country-by-country reporting; when taxpayers will need to comply with the DAC6 reporting rules; how individual countries will need to implement DAC6; the differences between a 'taxpayer' and an 'intermediary' in the context of DAC6; the responsibilities of taxpayers and intermediaries; which transactions are considered 'reportable transactions'; potential penalties for not complying with the DAC6 reporting requirements; the potential downsides for reporting transactions that may not be considered 'reportable transactions' under DAC6; and final words of wisdom for both taxpayers and intermediaries.

Whirlpool Decision: the Tax Court analyzes 'branch rules'

Tue, 26 May 2020 09:38:00 -0400

US Tax Reform Update: The final anti-hybrid regulations

Fri, 01 May 2020 09:38:00 -0400

The CARES Act: a primer for cross-border tax professionals

Fri, 10 Apr 2020 09:38:00 -0400

Global Tax Update: Around the world in 35 minutes

Fri, 13 Mar 2020 09:38:00 -0400

Merging lanes: key MA and international tax considerations after TCJA

Fri, 21 Feb 2020 08:38:00 -0500

Sourcing sorcery: New inbound taxation regs

Fri, 14 Feb 2020 08:38:00 -0500

Brexit stage left: See EU later

Fri, 31 Jan 2020 08:38:00 -0500

The New FTC Regs: Calculating tax in a galaxy far, far away

Mon, 20 Jan 2020 08:38:00 -0500

Tech Talk: How Leaders in Tax Embrace Technology

Fri, 03 Jan 2020 08:38:00 -0500

We got the BEAT: US Tax Reform Regulations

Fri, 20 Dec 2019 08:38:00 -0500

BEPS 2.0: It's easy as (Amounts) A, B, C

Fri, 06 Dec 2019 08:38:00 -0500

Reforma en México: A tax reform discussion

Mon, 25 Nov 2019 08:38:00 -0500

Properly attributing: a conversation on tax attribution after the TCJA

Fri, 08 Nov 2019 08:38:00 -0500

The Trade War: A Discussion on Trade and Tariffs

Fri, 25 Oct 2019 09:38:00 -0400

Clarity in the cloud: analyzing the new digital content and cloud computing regulations

Fri, 11 Oct 2019 09:38:00 -0400

No havering here: BEPS 2.0 goes beyond digital

Fri, 27 Sep 2019 09:38:00 -0400

Mic flip: Doug McHoney talks candidly about tax reform

Mon, 16 Sep 2019 09:38:00 -0400

Technically, you're not wrong, but we need a few TCJA corrections

Fri, 30 Aug 2019 09:38:00 -0400

Taxing Cryptocurrency: When a currency is not a currency

Tue, 20 Aug 2019 09:38:00 -0400

Invalidity: When and why are tax regulations invalid?

Mon, 05 Aug 2019 09:38:00 -0400

The DRD 245A regs: Did the donut hole eat the donut?

Tue, 23 Jul 2019 09:38:00 -0400

Branch FX: Were those Section 987 regulations final?

Tue, 09 Jul 2019 09:38:00 -0400

GILTI as charged - Part 2: The Final Regs and High Tax Exception

Tue, 25 Jun 2019 09:38:00 -0400

Tax Reform with a slice of Swiss

Mon, 10 Jun 2019 09:38:00 -0400

Mushy Peas: Comparing the UK and US's Corporate Tax Reforms

Fri, 24 May 2019 09:38:00 -0400

A Fortune 50 Tax VP's perspective on tax reform

Mon, 13 May 2019 09:38:00 -0400

A practitioner’s brief history of international tax in the US

Mon, 29 Apr 2019 09:55:00 -0400

US Tax Reform: An Insider’s Perspective for CFOs

Mon, 15 Apr 2019 09:55:00 -0400

FDII shades of gray

Mon, 01 Apr 2019 10:00:00 -0400

Doug McHoney (PwC's US International Tax Services Leader) interviews Alex Voloshko (PwC’s US Value Chain Transformation Leader) and Marco Fiaccadori (PwC Transfer Pricing Principal) about the recently released Foreign Derived Intangible Income (FDII) regulations under Section 250. Among other topics, they discuss how FDII interplays with GILTI, and how the FDII proposed regulations would apply to property transactions, component manufacturing, intangibles, and services.

Engineering the post-tax reform world: a policy perspective

Mon, 18 Mar 2019 09:55:00 -0400

Around the geopolitical (and tax) world in 30 minutes

Mon, 11 Mar 2019 09:55:00 -0400

Behind the Curtain: The Joint Committee on Taxation

Mon, 04 Mar 2019 08:55:00 -0500

Final Section 965 regulations: Amended tax returns ahead?

Mon, 18 Feb 2019 08:55:00 -0500

Temas candentes: Hot issues in Mexican tax

Mon, 04 Feb 2019 08:55:00 -0500

Anti-hybrid rules: the forgotten reform provisions

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