Cross-border Tax Talks

One big beautiful podcast: Part 2

Jun 26, 2025
In this enlightening discussion, Pat Brown, an International Tax Partner and Co-Leader at PwC’s Washington National Tax Services, shares his expertise on the intricate details of the 'One Big Beautiful Bill.' He and Doug McHoney delve into the complexities surrounding the legislative maze, including the urgent July 4th deadline and the challenges of aligning House and Senate bills. They discuss crucial changes to GILTI, FDII, and the BEAT, revealing how these modifications will impact both domestic and international taxpayers.
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INSIGHT

Byrd Rule Shapes Senate Bills

  • Reconciliation bills in the Senate can pass with a simple majority due to special rules.
  • The Byrd rule enforces that provisions must impact revenue and prohibits affecting Social Security funds.
INSIGHT

Senate Softens Section 899

  • Senate softens Section 899's impact by delaying effective date and limiting withholding rate increases.
  • Senate treats digital services taxes and UTPRs differently due to varied negotiation timelines.
ADVICE

Watch BEAT Changes Closely

  • Taxpayers in jurisdictions with UTPR or DST must closely monitor BEAT rules due to elimination of gross receipts test.
  • Ignoring BEAT changes can lead to unexpected tax liabilities.
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