Tom Patten

Tom Patten, a London-based US International Tax Partner at PwC, dives into the complex and often overlooked Sections 891 and 899 of the U.S. tax code. He discusses the upcoming executive order that aims to address discriminatory foreign taxes and its potential repercussions for non-US citizens. The conversation shifts to proposed changes to the BEAT rules, focusing on how these retaliatory measures could affect multinational corporations. With insights into navigating this evolving landscape, Patten provides essential advice for companies facing uncertain tax regulations.