Cross-border Tax Talks

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.

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.

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.

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 re...

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...

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.

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, eff...

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...

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...

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.

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 - an...

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 insuran...

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 T...

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 proces...

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 S...

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 rep...

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 minimu...

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 c...

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 decision...

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 technolog...

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 corpora...

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; ...

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 L...

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 cove...

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 SP...