Pat Brown

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.

Pat Brown, an International Tax Partner at PwC and former Deputy International Tax Counsel, joins Doug McHoney to discuss the 'One Big Beautiful Bill.' They dive into its legislative path in Congress and its implications for both domestic and international taxpayers. Key topics include temporary business provisions, the impact of Section 899 on digital services taxes, and the evolving treatment of research expenses. They also tackle the complexities of U.S. tax credits under global minimum tax rules and international negotiations surrounding the Undertaxed Profits Rule.

Pat Brown, International Tax Partner at PwC and former VP of Tax at General Electric, joins Doug McHoney to discuss the evolving landscape of U.S. corporate tax policy. They dive into the implications of recent regulations, including disregarded payment loss rules and cloud sourcing. With a new administration, they assess the fate of these rules and the ticking time bomb of expiring provisions from the 2017 Tax Cuts and Jobs Act. The conversation also touches on international tax challenges and the U.S. response to OECD proposals, providing valuable insights for businesses navigating the future.