Cross-border Tax Talks
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- 222
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- Último episodio
- 2 Nov 2026
Sobre el podcast
PwC specialists share insights and perspectives on key issues impacting the ever-changing tax landscape. Our podcasts aim to provide quick, easy and up-to-date tax developments to help you stay current and competitive in today's challenging business environment. Listen to episodes at your convenience via your desktop computer or smart device.
Episodios 222
Pillar Two update: More filing challenges
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Phil Ramstetter, a Chicago-based International Tax Partner at PwC and Pillar Two subject matter specialist. Phil previously served as a …
Notas del episodio
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Phil Ramstetter, a Chicago-based International Tax Partner at PwC and Pillar Two subject matter specialist. Phil previously served as a tax policy consultant at Business at OECD (BIAC). Doug and Phil discuss the evolving Pillar Two landscape, including the OECD’s 2026 guidance, BIAC’s role in shaping workable rules, and the side-by-side and UPE safe harbors. They examine UTPR allocation and GIR validation problems arising from differences in domestic laws, alongside new guidance on explicitly conditional taxes and mismatched QDMTT fiscal years. The conversation also covers revised GIR and XML reporting, continuing QDMTT compliance for US-parented groups, upcoming guidance on related benefits and integrity measures, and why greater taxpayer input, prospective rulemaking, and filing standardization are essential to meaningful simplification.
Still tariffied: Refunds, reshoring and risk
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Chris Desmond, leader of PwC US’s Global Trade Services practice and, as Doug puts it, a 'reformed Transfer Pricing Partner.&apos …
Notas del episodio
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Chris Desmond, leader of PwC US’s Global Trade Services practice and, as Doug puts it, a 'reformed Transfer Pricing Partner.' Doug and Chris, recording at PwC’s 2026 Global Transfer Pricing, Trade, and Indirect Taxes Conference in Chicago, discuss the progress of IEEPA tariff refunds and the related accounting, legal-entity, and transfer pricing decisions; continuing US tariff authority and trade tensions involving China, the European Union, Canada, and Mexico; and selective supply-chain reshoring. They also examine pharmaceutical tariff developments, White House deals, customs valuation and reconciliation, first-sale planning, and heightened audit exposure. The conversation closes with AI’s potential and limitations in trade compliance and three priorities for tax leaders: aligning customs and tax data, coordinating transfer pricing adjustments, and scenario planning.
A regulatory balancing act: Recent US guidance
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Wade Sutton, International Tax Leader of PwC’s Washington National Tax Services practice and guest host of Cross-border Tax Talks …
Notas del episodio
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Wade Sutton, International Tax Leader of PwC’s Washington National Tax Services practice and guest host of Cross-border Tax Talks. After Wade reflects on his previous experience at the US Treasury Department, he and Doug discuss four proposed regulation packages under the One Big Beautiful Bill Act (OB3): expense allocation for net CFC tested income (NCTI) and foreign-derived deduction-eligible income (FDDEI), FDDEI eligibility changes, CFC pro rata share rules, and repeal of the one-month deferral election. They examine foreign tax credit limitations, overall domestic loss exposure, M&A drafting and tax-year elections, and transition relief. The conversation also covers reconciliation prospects, regulatory comment periods, Loper Bright’s influence on Treasury’s approach, and anticipated guidance on foreign sales branches and foreign-controlled CFCs.
When regs lose their deference: Three cases rewrite the tax playbook
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Laura Williams, an international tax partner in PwC’s Washington National Tax Services office and former branch chief in the IRS Office …
Notas del episodio
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Laura Williams, an international tax partner in PwC’s Washington National Tax Services office and former branch chief in the IRS Office of Chief Counsel. Doug and Laura discuss the role of Treasury regulations, Section 7805(a), and the post-Loper Bright limits on agency deference and delegated authority. They explain why TCJA’s mismatched effective dates created a ‘donut hole’ and examine three recent regulation-validity decisions: Varian Medical Systems, Keysight Technologies, and Siemens Medical Solutions. These cases concern the Section 78 gross-up, GILTI deductions, extraordinary dispositions, and the Section 245A dividends-received deduction. The conversation also addresses judicial precedent, protective refund claims, return and financial-statement positions, possible government appeals, and the IRS’s potential use of economic substance and other alternative arguments when challenged regulations do not survive.
Measure Twice, Elect Once: The Latest Section 987 Regs
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Laura Valestin, an international tax partner in PwC’s Washington National Tax Services office, who specializes in the taxation of …
Notas del episodio
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Laura Valestin, an international tax partner in PwC’s Washington National Tax Services office, who specializes in the taxation of financial transactions, including foreign currency. Doug and Laura discuss the proposed Section 987 regulations governing the new CFC election, beginning with the rule’s scope, history, and common QBU fact patterns. They explain how the election can turn off future Section 987 gain-or-loss computations, while preserving translation and basis-tracking requirements, and examine consistency across commonly controlled CFCs, partnership applications, inbound transactions, and the loss of future Section 987 losses. They also cover the 120-month amortization of pre-election amounts, the $50 million asset threshold, election timing and filing mechanics, reliance on the proposed rules, the November 12 comment deadline, and why detailed modeling is essential before making an effectively irrevocable choice.
Globalized State Aid: Understanding Europe’s Foreign Subsidies Regulation
Wade Sutton, PwC’s International Tax Leader for the Washington National Tax Services Office, fills in as host while Doug is away on assignment. Wade welcomes Will Morris, PwC’s global tax policy lead and former …
Notas del episodio
Wade Sutton, PwC’s International Tax Leader for the Washington National Tax Services Office, fills in as host while Doug is away on assignment. Wade welcomes Will Morris, PwC’s global tax policy lead and former chair of the AmCham EU Tax Committee. In this episode, Wade and Will discuss the EU Foreign Subsidies Regulation (FSR). They cover its state-aid origins, reach into M&A and public procurement, and early enforcement record. The episode examines the European Commission’s recent assessment, possible reductions in reporting burdens, and the three-step analysis from foreign financial contribution (FFC) to subsidy to market distortion. The conversation also covers tax incentives and credits, Inflation Reduction Act and Pillar Two interactions, data-collection challenges, geopolitical considerations, standstill risks, and practical steps before an EU transaction or procurement bid.
Portal Combat 2: Pillar Two compliance post-mortem
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Pat Coughlin, a Chicago-based tax director in PwC’s Quantitative Solutions and Technologies Practice within International Tax Services …
Notas del episodio
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Pat Coughlin, a Chicago-based tax director in PwC’s Quantitative Solutions and Technologies Practice within International Tax Services and a former Notre Dame running back. Doug and Pat discuss the June 30, 2026, Pillar Two compliance post-mortem, including PwC’s experience filing more than 50,000 returns with a success rate above 99%. They dive into how business rules and filing capabilities were built across dozens of jurisdictions, what late portals and conflicting validations revealed about the system, why the OECD and local tax authorities should act quickly on timely-filed GIR relief, a longer 2025 filing deadline, clearer amended-return mechanics, and broader simplification. They close with practical advice for 2025: start now, focus on calculations, and narrow review to the sections that matter most.
Japan Tax Update: Tea, Tariffs and Top-up Taxes
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Shin Yamaguchi, a tax partner at PwC Japan, the Japanese inbound tax leader, and host of the English-language podcast Dial in Japan …
Notas del episodio
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Shin Yamaguchi, a tax partner at PwC Japan, the Japanese inbound tax leader, and host of the English-language podcast Dial in Japan. Doug and Shin discuss Japan’s current inbound and outbound investment environment, the role of supply-chain diversification and energy security in Japanese outbound strategy, and why Japan remains an active market for inbound acquisitions and carve-outs. They also explore Japan’s Pillar Two implementation timeline, readiness for compliance, the interaction between Pillar Two and Japan’s CFC rules, practical administrative and substantive challenges for Japanese-parented groups, tariff-related uncertainty for US investment, and the tax controversy environment in Japan, including the continued focus on transfer pricing.
Taiwan Update: Treaties, Tariffs and Top-Up Tax Turbulence
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Paulson Tseng, PwC Taiwan’s International Tax Services and Transfer Pricing Leader, the firm’s Human Capital Leader, and host of the …
Notas del episodio
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Paulson Tseng, PwC Taiwan’s International Tax Services and Transfer Pricing Leader, the firm’s Human Capital Leader, and host of the Finance and Tax Cafe podcast.
Doug and Paulson discuss Taiwan’s corporate tax framework, including the 20% corporate rate, foreign tax credit limits, withholding tax friction for services, and CFC rules; how inbound investment remains strong in semiconductors and R&D while outbound models are shifting toward more diversified, multi-nodal footprints; Taiwan’s current Pillar Two posture, top-up tax exposure, and readiness challenges around data, education, and compliance; whether Pillar Two is already changing business behavior; tax controversy themes in Taiwan, especially transfer pricing, withholding tax, and risk-based audits; and Paulson’s own podcast and its broader finance, economic, and workplace-stress topics.
No strait answers: Energy shocks, AI stocks, and trade talks
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Dr. Alexis Crow, partner and Chief Economist for PwC US. Prior to joining PwC, Alexis taught at the London School of Economics. Doug …
Notas del episodio
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Dr. Alexis Crow, partner and Chief Economist for PwC US. Prior to joining PwC, Alexis taught at the London School of Economics. Doug and Alexis discuss the macroeconomic and geopolitical implications of the Iran conflict, including energy-market scarring, oil-price scenarios, fiscal supports, inflation pressures, and central-bank constraints. They also examine the durability of US growth, AI-driven investment, consumer demand, and private credit risk; then move through global trade developments and regional dynamics across Asia-Pacific, Latin America, Europe, and North America. The conversation closes with the “re-industrial era,” energy addition, automation, workforce skills, and financial-stability risks that may be underappreciated.
Portal Combat: Pillar Two Forms, Deadlines, and the Fight for Certainty
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Will Morris, PwC’s Global Tax Policy Leader, at PwC’s Asia-Pacific Global Tax Symposium in Hong Kong. Will previously chaired the …
Notas del episodio
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Will Morris, PwC’s Global Tax Policy Leader, at PwC’s Asia-Pacific Global Tax Symposium in Hong Kong. Will previously chaired the Business and Industry Advisory Committee (BIAC) Tax Committee for 10 years. Doug and Will discuss the acute uncertainty surrounding Pillar Two filing readiness as initial 2024 calendar-year deadlines approach, including the OECD’s May 18, 2026, common understanding document, GIR central filing, local filing portals, XML schema differences, penalty relief, safe harbor elections, QDMTT and top-up tax returns, taxpayer outreach to BIAC, the OECD, and national governments, the OECD implementation toolkit, 52/53-week fiscal-year UTPR guidance, and unresolved dispute resolution questions.
Mexico tax update: Nearshoring, audits, and treaty twists
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Adriana Rodriguez, a PwC international tax partner based in Mexico City, for a discussion recorded at PwC’s International Tax …
Notas del episodio
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Adriana Rodriguez, a PwC international tax partner based in Mexico City, for a discussion recorded at PwC’s International Tax Conference. Doug and Adriana discuss the core features of Mexico’s corporate tax system, including corporate income tax, withholding taxes, VAT, inflation adjustments, CFC rules, capital gains planning, and the impact of the multilateral instrument on treaty access. They also explore whether Mexico is likely to adopt Pillar Two, how Mexican multinationals are preparing for compliance, the role of incentives in inbound investment, the continued relevance of the maquila regime, rising audit and transfer pricing pressure, expanding tax authority digitization, and practical lessons for multinationals investing in Mexico.
Tariff Strike Zone: IEEPA Refunds, Audit Pressure, and Fragmented Trade
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 …
Notas del episodio
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
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 …
Notas del episodio
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
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 …
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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
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 …
Notas del episodio
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
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 …
Notas del episodio
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
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 …
Notas del episodio
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
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 …
Notas del episodio
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
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 …
Notas del episodio
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
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 …
Notas del episodio
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
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 …
Notas del episodio
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
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 …
Notas del episodio
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
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 …
Notas del episodio
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
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 …
Notas del episodio
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
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 …
Notas del episodio
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
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 …
Notas del episodio
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
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 …
Notas del episodio
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!
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 …
Notas del episodio
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
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 …
Notas del episodio
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.
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