Potential Year-End Tax Bill Negotiations and Key Issues

Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s Tax Leadership Conference in breezy Orlando with Pat Brown, frequent pod guest and co-leader of PwC’s Washington National Tax Services. They discuss US tax updates, including the status and fate of the Tax Cuts and Jobs Act (TCJA); the future of Section 163(j); notices and guidance from Treasury, including the recent Section 174 notice 2023-63; FTC relief notice, and what to anticipate in the coming months and years with respect to foreign tax creditability; what’s included and what’s not included under the corporate alternative minimum tax (CAMT); Section 367(b) ‘Killer B’ regulations; and the Moore case.