Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Steve Kohart, an International Tax Principal in PwC’s New York City office and former advisor to the OECD’s Center for Tax Policy and Administration. Doug and Steve discuss the OECD’s latest administrative guidance on Pillar Two, covering key changes to transition rules, deferred tax asset adjustments, tax credits, and compliance burdens for multinational corporations. They dive into the OECD’s focus on Bermuda and Switzerland, new anti-abuse measures, implications of the Qualified Domestic Minimum Top-up Tax (QDMTT), and the complexities of the new Globe Information Return (GIR). The conversation also explores the political and procedural challenges in implementing additional guidance, particularly in light of the new US administration’s stance on Pillar Two. 

Rebecca Lee, an International Tax Principal at PwC specializing in financial transactions and digital assets, joins Doug McHoney for a deep dive into the final and proposed regulations under Section 987. They explore methods for calculating foreign currency gains and losses for qualified business units, major changes in regulations, and implications for partnerships. The conversation also highlights the historic context and discusses the significance of compliance amidst upcoming 2024 changes, stressing the need for taxpayers to stay informed and proactive.

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Tadd Fowler, Senior Vice President Treasurer and Global Taxes of Procter & Gamble. With nearly two decades at P&G, Tadd shares insights from his dual leadership in tax and treasury. Doug and Tadd discuss P&G’s approach to tax certainty, compliance in over 180 jurisdictions, and the strategic benefits of operating on a single ERP platform. They delve into US tax policy, the impacts of the Tax Cuts and Jobs Act, and P&G’s commitment to transparency and tax advocacy. Additional topics include preparing for Pillar Two compliance, managing ESG taxation, and adapting to evolving global tax landscapes.  See P&G’s Approach to Tax. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Laura Williams, an International Tax Principal at PwC’s Washington National Tax Services office. Laura previously worked as the International Branch Chief at the IRS Office of Chief Counsel. Doug and Laura discuss the long awaited previously taxed earnings and profits (PTEP) proposed regulations. Together they walk through the core aspects of the PTEP regime, including PTEP accounting, increases and decreases to basis of stock and other property, foreign currency gain or loss, allocation of foreign tax credits, 'covered distributions’, US consolidated group rules, and the anti-avoidance rule. See our PwC Tax Insight for more details. 

Will Morris, PwC’s Global Tax Policy Leader and former Director of Global Tax Policy at General Electric, shares insights on the intricate world of global tax policy. He discusses the intersection of tax and trade, emphasizing the need for a cohesive strategy amidst geopolitical shifts. Will also delves into digital services taxes and their potential impact on multinational corporations. The conversation touches on Pillar Two, highlighting how the UnderTaxed Payments Rule could reshape the landscape, and the evolving role of the UN in global tax reforms.

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Andy Wiggins, PwC Partner based in the United Kingdom and PwC’s Global Tax Accounting Services Leader to(birming)ham it up on the tax accounting implications of Pillar Two. Together they discuss, deferred accounting, the differences between US Generally Accepted Accounting Principles (GAAP) and International Financial Reporting Standards (IFRS), accounting implications of the qualified domestic minimum top-up tax (QDMTT), income inclusion rule (IIR), and undertaxed profits rule (UTPR), country by country reporting (CbCR), and transitioning from the full safe habor to GloBe rules. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by returning guest Matt Ryan, a PwC International Tax Partner based in London and leader of PwC UK’s International Tax and Treasury Network. Doug and Matt discuss a selective list of Pillar Two issues and topics related to the UK Finance Bill 2024-25. They provide an update on the latest Pillar Two happenings, including the transposition of the June 2024 OECD Administrative Guidance into UK law, the potential for retroactive provisions, UK compliance requirements, the potential for changes in light of the US election, and what could be next. 

Stewart Brant, Managing Director at PwC’s Tax Policy Services, shares his expertise on international tax policy and the Pillar Two initiative. The conversation navigates the current global enactment of Pillar Two, revealing varied country applications and retroactive rules. They also discuss potential impacts of a Trump administration and the UN's evolving role in shaping these policies. The light-hearted baseball banter adds a unique touch to the serious discussions, making tax compliance a bit more engaging.

Join Rohit Kumar, PwC’s National Tax Co-leader and former deputy chief of staff to Senator Mitch McConnell, as he dives into the implications of recent U.S. election results on tax policy. He discusses the potential for significant tax reform under a republican-controlled Congress, the challenges of achieving bipartisan support, and the forthcoming must-pass legislation in 2025. Rohit also sheds light on tariff policies, the fate of OECD’s Pillar One and Two, and what these changes could mean for international corporations navigating a complex landscape.

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Pieter Dere, Tax Partner in PwC Belgium, part of PwC’s International Tax and Transfer Pricing Group, and PwC Belgium’s Pillar Two leader. Doug and Pieter cover the latest Pillar Two developments in Belgium, including how Belgium is incorporating the latest Pillar Two administrative guidance, how tax authorities are preparing, advance tax payments, registration requirements, the Qualified Domestic Minimum Top-up Tax (QDMTT) return, the interaction of the Belgium patent box regime with Pilar Two, and the constitutionality of the Undertaxed Profits Rule (UTPR), among other topics.