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.

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).