Cross-border Tax Talks

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.

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.

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!

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.

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.

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.

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.

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.

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.

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.