Doug McHoney

PwC's International Tax Services Global Leader Doug McHoney and ITS Partner Rebecca Lee discuss the history and challenges of Section 987 regulations on foreign exchange gains/losses for foreign branches. They analyze the 250-page package of the proposed regulations, its limitations, and its impact on industries like banking and insurance. The hosts also explain the implications for deferred tax assets, liabilities, and pillar two global minimum tax calculations.

Doug McHoney and Dr. Alexis Crow from PwC discuss recession outlook, impact of inflation, central banking policy, commercial real estate challenges, currencies, energy transition, US election outlook, and economic forecasts for Japan, India, Singapore, Brazil, the Middle East, and Europe.

Exploring the revolutionary OECD Pillar Two global tax system for multinational companies, its impact on businesses worldwide, the four operating rules, enactment timing, implications for US companies, mechanics comparison, practical considerations, data and controls implications, and final advice.

Doug McHoney and Nils Cousin discuss tax treaties, mutual agreement procedures, competent authority, recent US tax treaty activities, treaty shopping, the USMCA Trade Agreement, and the future of tax treaties in the United States. Specific treaties discussed include those with Chile, Croatia, Hungary, Taiwan, and Russia.

Doug McHoney (PwC's US International Tax Services Global Leader) is joined by Mike Olecki, PwC’s International Tax Services Global Technology Leader and partner in the Quantitative Services Tax Practice. Doug and Mike discuss the OECD Pillar Two documents released in December 2022, including the transitional CbyCR safe harbour, the potential for a permanent safe harbour, the GloBE Information Return, calculation challenges, and how technology can help.

Doug McHoney and David Ernick discuss the transitional safe harbor rules for Country-by-country reporting (CbCR) in this podcast. They cover topics such as the safe harbor tests, exclusions, and differences between safe harbor and full GLoBE rules. They also discuss the history and implementation of public CBCR, challenges of transfer pricing adjustments, and the importance of Advance Pricing Agreements (APAs).

Doug McHoney, PwC's International Tax Services Global Leader, and Will Morris, PwC's Global Tax Policy Leader, discuss the progress of Pillar Two. They explore the administration and adjudication process, potential FAQs and future guidance from the OECD, the recent EC guidance, retroactive OECD guidance implementation, and business participation in the process.

Doug McHoney, PwC’s International Tax Services Global Leader, teams up with Janice Mays, a veteran of tax policy with 40 years in government. Together, they dissect how the upcoming U.S. elections could reshape tax policy. They discuss key Senate and House races to watch, explore bipartisan challenges in tax reform, and examine the potential effects of election outcomes on corporate tax rates. The conversation also tackles the complexities of the GUILTY proposal and its implications for corporate adaptation amidst shifting political dynamics.

Doug McHoney and Phil Ramstetter discuss OECD's Admin Guidance on Pillar 2, focusing on DTL recapture rule, cross-border tax allocation, GloBE rules, entity classification, and more. They highlight challenges in simplifying tax rules, global accounting, and enacting OECD guidance into national laws.

Doug McHoney, PwC's International Tax Services Global Leader, discusses US tax updates, including the fate of the Tax Cuts and Jobs Act. They also talk about Section 163(j), Treasury notices and guidance, foreign tax creditability, corporate alternative minimum tax, Section 367(b) regulations, and the Moore case.