Wade Sutton, PwC's Washington National Tax Service's ITS Leader, and Doug McHoney discuss recent US tax guidance including foreign tax credit, corporate alternative minimum tax, and previously taxed E&P notices. They also explore the interaction of Pillar Two with FTC rules and CAMT, while looking ahead to potential guidance in 2024.
International tax offers job security and intellectual challenge, driving professionals towards the field.
Recent US tax guidance covers Pillar Two interaction with FTC rules and complexities of CAMT.
Deep dives
PWC's Pillar 2 Engine: A Game Changer for Tax Modeling and Compliance
PWC introduces the Pillar 2 engine as a revolutionary tool for modeling, provision, and compliance calculations. This centralized rules engine, developed by a global team of tax experts, leverages over 20 years of international tax technology. The Pillar 2 engine is available as a service and will be licenseable in July, providing advanced capabilities for tax professionals worldwide.
Career Path in International Tax: Job Security and Intellectual Challenge
Wade Sutton highlights the benefits of pursuing a career in international tax, emphasizing job security and the continuous intellectual challenge it offers. With tax codes becoming increasingly complex, there is a growing demand for tax practitioners who play a crucial role in companies' financial strategies. He also emphasizes the rewarding nature of solving tax-related puzzles, making international tax a stimulating and dynamic field for professionals.
US Tax Developments: Foreign Tax Credit Rules and Notice 2023-80
The podcast discusses recent US tax guidance, including Notice 2023-80, which addresses foreign tax credit rules. The notice defers the application of final foreign tax credit regulations, providing relief amid evolving regulatory changes. It also covers the credibility of certain taxes under Pillar 2 and their interaction with domestic consolidated losses, offering insights into navigating complex tax regulations.
Impact of US KAMT on International Tax Planning and Compliance
The podcast delves into the Corporate Alternative Minimum Tax (KAMT) rules and their implications for multinational corporations. By calculating tax liabilities based on applicable financial statement income, KAMT introduces complexities in international tax planning and compliance. The discussion highlights the need for careful attention to detail to ensure accurate reporting and compliance with evolving tax regulations.
On this episode, Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Wade Sutton. Wade is PwC’s Washington National Tax Service’s ITS Leader, a former adjunct professor of international tax at Georgetown University's Law Center, and former Deputy International Tax Counsel, US Treasury. Doug and Wade discuss what drove them to international tax as a career (spoiler: job security) before diving into recent US tax guidance. They discuss the recent foreign tax credit (FTC), corporate alternative minimum tax (CAMT) and Previously taxed E&P (PTEP) notices. They also discuss the interaction of Pillar Two with the FTC rules, dual consolidated loss (DCL) rules, and CAMT. Doug and Wade wrap up by looking ahead to guidance we might see in 2024.
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