Cross-border Tax Talks

US Guidance Update: Pillar Two and more

Feb 13, 2024

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.

46:35

Episode guests

Wade Sutton

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Quick takeaways

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.

Preventing Circularity in Taxation for Minority Shareholders

00:55

Thorough Review of Recent Tax Notices

01:04

Complex Tax Issues and the Importance of Basis Credit

01:36

Avoiding Double Counting in International Taxation

01:06

Introduction

2min

Recent Guidance on Foreign Tax Credit Rules in the US

5min

Navigating Complexity: US Foreign Tax Credit Ability Rules

19min

Navigating Covered Inbound Transactions and Potential Traps for Companies

3min

Navigating Complexities of US Corporate Tax Laws and OECD Guidance

12min

Exploring Purchase Price Adjustments in Acquisitions and Fair Market Value Book Basis

2min

Anticipated Tax Guidance Updates and Regulatory Developments

3min

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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Cross-border Tax Talks

US Guidance Update: Pillar Two and more

Episode guests

Podcast summary created with Snipd AI

Quick takeaways

Deep dives

PWC's Pillar 2 Engine: A Game Changer for Tax Modeling and Compliance

Career Path in International Tax: Job Security and Intellectual Challenge

US Tax Developments: Foreign Tax Credit Rules and Notice 2023-80

Impact of US KAMT on International Tax Planning and Compliance

Preventing Circularity in Taxation for Minority Shareholders

Thorough Review of Recent Tax Notices

Complex Tax Issues and the Importance of Basis Credit

Avoiding Double Counting in International Taxation

Remember Everything You Learn from Podcasts