Cross-border Tax Talks

Matt Ryan, London-based international tax partner and PwC UK’s Pillar Two Leader, joins Doug McHoney to discuss the challenge UK legislators face in enacting legislation while the OECD guidance is still changing. They explore practical next steps for UK-parented taxpayers, complexities created by UK rules around safe harbors, and issues with partnerships and deferred taxes.

Doug McHoney, PwC's International Tax Services Global Leader, and Will Morris, PwC's Global Tax Policy Leader, discuss the progress of Pillar Two. They explore the administration and adjudication process, potential FAQs and future guidance from the OECD, the recent EC guidance, retroactive OECD guidance implementation, and business participation in the process.

Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s Global Transfer Pricing Conference where he’s joined by Giorgia Maffini. Giorgia is part of PwC’s Global Transfer Pricing team in London and was previously the Deputy Head of the Tax Policy and Statistics Division at the OECD. Doug and Giorgia discuss why taxpayers should care about Pillar One, starting with the basics - what is Pillar One and how does it work with Pillar Two? They discuss the complexities, scope and impacts of both Amount A and Amount B. Also the timing, economic impact, and what’s next. Finally, they address what might happen with digital services taxes and what companies should do next.

Doug McHoney and David Ernick discuss the transitional safe harbor rules for Country-by-country reporting (CbCR) in this podcast. They cover topics such as the safe harbor tests, exclusions, and differences between safe harbor and full GLoBE rules. They also discuss the history and implementation of public CBCR, challenges of transfer pricing adjustments, and the importance of Advance Pricing Agreements (APAs).

Doug McHoney, PwC's International Tax Services Global Leader, discusses US tax updates, including the fate of the Tax Cuts and Jobs Act. They also talk about Section 163(j), Treasury notices and guidance, foreign tax creditability, corporate alternative minimum tax, Section 367(b) regulations, and the Moore case.

Doug McHoney and Nils Cousin discuss tax treaties, mutual agreement procedures, competent authority, recent US tax treaty activities, treaty shopping, the USMCA Trade Agreement, and the future of tax treaties in the United States. Specific treaties discussed include those with Chile, Croatia, Hungary, Taiwan, and Russia.

Doug McHoney (PwC's International Tax Services Global Leader) and Wade Sutton (former Deputy International Tax Counsel for the US Treasury and newly appointed ITS leader of PwC’s Washington National Tax Practice) are back in Washington, D.C. to discuss the recent Supreme Court grant of certiorari for the Moore v. US case. Doug and Wade go back to their law school days to break down the Moore case, starting with the facts, procedural history, and the potential implications if Section 965 is ruled unconstitutional, including direct taxation, indirect taxation, subpart F, Section 245A, GILTI, and, as always, Pillar Two.

Doug McHoney (PwC's International Tax Services Global Leader) and Ken Buttenham meet up in PwC’s Washington, D.C.. studio. Ken leads PwC Canada’s International Tax Practice from Toronto. Doug and Ken kick off with a discussion on Doug’s favorite Canadian food, then dive into the Canadian Pillar Two proposals, discussing the Global Minimum Tax Act (GMTA), UTPR, IIR, QDMTT, compliance, the GloBE Information Return, and tax incentives. They also cover digital services taxes (DSTs), the excessive interest and financing expenses limitation (EIFEL) rules, and the Canadian General Anti-Avoidance Rule (GAAR).

Doug McHoney (PwC's International Tax Services Global Leader) and Jesse Kavanaugh (PwC Hong Kong SAR’s Tax Reporting & Strategy Leader) met up at PwC’s AsiaPac Global Tax Symposium in Singapore. Jesse is an International Tax Partner in Hong Kong SAR and has been leading the region’s Pillar Two tax efforts. They discuss the state of play of Pillar Two in Hong Kong SAR, trends regarding safe harbours and data collection, modeling and calculations challenges, the centralized and decentralized approaches to Pillar Two inherent to the region, and the Hong Kong SAR legislative process. They also touch on the addition of Hong Kong SAR to the EU’s ‘grey list’ and the recent introduction of the Foreign Source Income Exemption (FSIE) Regime for Passive Income.

Doug McHoney (PwC's International Tax Services Global Leader) is back at Westminster Studios in St. Louis, Missouri where he’s joined by Steve Kohart, International Tax Principal with PwC in New York City and former Advisor for the Center for Tax Policy and Administration for the OECD. Together they discuss the latest wave of OECD Pillar Two guidance including the Subject-to-Tax-Rule (STTR), UTPR safe harbour, qualified domestic minimum top-up tax (QDMTT) safe harbour, marketable transferable tax credits (MTTCs), as well as the six key pieces of the substance base income exclusion (SBIE).