Cross-border Tax Talks

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 systems, the importance of working as a team, how software tools can help, and the power of a centralized rules engine.PwC’s Data Input Catalog

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 history lesson on Pillar Two, when it was merely the Digital Project. Topics covered include blended CFC regimes, GILTI, expense apportionment, loss-making jurisdictions, transition period transactions, common control, the outlook for future guidance and some of the remaining open questions.

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 story, the challenges and successes of the project, harmful tax practices and the ways the OECD is trying to change tax systems, the natural complexity of tax, the future of tax incentives, compliance requirements, the private sector’s role in the policy process and much more.

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, including the safe harbor rules, depreciation adjustments, M&A considerations, comparisons to Pillar Two, and much more.

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 Return, calculation challenges, and how technology can help.

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 pricing rulings, and the progress made on Pillar One & Two.

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 requirement, the attribution requirement for withholding tax on royalty payments, and the definition of a reattribution asset for purposes of allocating and apportioning foreign taxes.

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 transfers, the Maquiladora regime, the Mexican manufacturing industry more broadly including business transformations and ‘near shoring,’ and debt structures and the ‘inflation adjustment’ in Mexico. Not surprisingly, Pillar Two makes a cameo appearance.

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 inclusion rule, and the under taxed payments rule. They also cover the finer points of UK’s treatment of asset transfers, deferred taxes, year-end adjustments, and the system and data requirements that companies must address.

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 accounting talent war, recent global tax changes, and the potential changes on the horizon.