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Cross-border Tax Talks

US Tax Policy: What’s Staying, What’s Going, and What’s Next?

Feb 27, 2025
Pat Brown, International Tax Partner at PwC and former VP of Tax at General Electric, joins Doug McHoney to discuss the evolving landscape of U.S. corporate tax policy. They dive into the implications of recent regulations, including disregarded payment loss rules and cloud sourcing. With a new administration, they assess the fate of these rules and the ticking time bomb of expiring provisions from the 2017 Tax Cuts and Jobs Act. The conversation also touches on international tax challenges and the U.S. response to OECD proposals, providing valuable insights for businesses navigating the future.
48:34

Episode guests

Podcast summary created with Snipd AI

Quick takeaways

  • The finalization of disregarded payment loss regulations represents a significant shift in U.S. tax policy, impacting multinational corporations with foreign subsidiaries.
  • Recent updates to cloud transaction regulations aim to clarify compliance for taxpayers while adapting to modern business models and incorporating familiar state tax concepts.

Deep dives

PwC's Pillar 2 Engine

PwC has developed a cloud-based centralized rules engine for Pillar 2 modeling, compliance calculations, and provisions, leveraging over two decades of international tax technology. This innovative engine, designed by a team of experts, aims to streamline the complexities inherent in Pillar 2 tax regulations. By integrating advanced technology, PwC intends to enhance the accuracy and efficiency of tax compliance for multinational corporations. The engine is currently available as a service, signaling a significant advancement in the tools available for managing international tax obligations.

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