Cross-border Tax Talks

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 val...

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 t...

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 imp...

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...

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...

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) expen...

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...

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 Representat...

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 Congr...

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 sim...

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 prop...

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'...

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 I...

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; majo...

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 in...

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...