Cross-border Tax Talks

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...

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 I...

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 Euro...

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 sy...

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 his...

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 s...

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...

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...

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 prici...

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...

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...

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 inclu...

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 accou...

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, regiona...

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 a...

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 an...

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,...

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 a...

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 d...

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 Mi...

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 ho...

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 policymake...

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 com...

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.

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.