Cross-border Tax Talks

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Nita Asher, an international tax principal in PwC’s Washington National Tax Services practice focused on inbound multinationals, with prior government experience during the TCJA. Doug and Nita discuss the One Big Beautiful Bill Act (“OB3”) and its impact on inbounds, including permanent 100% bonus depreciation; new Section 168N for qualified production property; Section 163(j)’s EBITDA-based ATI; the reworked ‘FDDEI’ (formerly FDII) and its 14% rate with outbound IP limits; shifting IRA credit timelines and ‘foreign entity of concern’ issues; BEAT’s modest rate bump to 10.5% and unchanged credit treatment; the potential future of Section 899; and CAMT interactions. Throughout, they emphasize modeling to avoid BEAT/CAMT whipsaws while capturing OBBBA cash-flow benefits.

Raza Janjua, a Director at PwC’s NYC ITS practice and an authority on hybrid arbitrage, dives into the intricate world of international tax transformations. He dissects the origins of BEPS Action 2 and how it paved the way for complex hybrid arbitrage rules. The conversation uncovers real-life pitfalls, from preferred equity classifications to cross-border compliance challenges. Raza also speculates on future guidance from the G7 and its implications for U.S. tax laws, emphasizing the necessity for clearer frameworks in an evolving landscape.

In this enlightening discussion, Craig Stronberg, Senior Director of PwC Intelligence and former national security expert, shares insights on the shifting landscape of U.S. global policy and rising powers like BRICS. He dives into the complexities of protectionism, globalization debates, and how multinational firms navigate uncertainty through risk management and scenario planning. They also explore the surprising link between national happiness and trade success, emphasizing that prioritizing citizen well-being can unlock significant growth opportunities.

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Mike Urse and Calum Dewar, both retiring PwC International Tax partners with decades-long careers in cross-border tax. Mike served as PwC’s US ITS Leader, while Calum built his career across PwC UK and PwC US, specializing in European and global tax systems. Doug, Calum and Mike discuss the dynamic nature of international tax and the intellectual curiosity that drew them to the profession. They also reflect on the evolution of PwC’s international tax practice, consensus-driven leadership, and building high-performing teams. The trio shares stories on mentorship, the impact of technology - from dictaphones to AI - and how global tax reform has shaped the practice. With humor and candor, they offer career advice to current and future tax professionals and celebrate the relationships, challenges, and learning that have defined their time at PwC. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Pat Brown, an international tax partner and Co-Leader of PwC’s Washington National Tax Services practice and former US Treasury’s Associate International Tax Counsel. In part three of Doug’s three-part OBBBA discussion with Pat, they discuss the newly enacted OB3 reconciliation law, focusing on its permanent corporate and individual tax provisions, the recalibration of bonus depreciation, Section 174 expensing and Section 163(j); the Senate’s redesign of GILTI, FDII and BEAT; Inflation Reduction Act rollbacks; Treasury’s last-minute removal of Section 899; and the G7’s surprise accord intended to exempt US-parented groups from Pillar Two’s IIR and UTPR while elevating QDMTTs and compliance simplification. They map the procedural and legislative steps still needed, potential timing gaps, and why multinational groups must keep Pillar Two compliance front-of-mind.  

In this engaging discussion, Jesse Kavanaugh, an international tax partner at PwC Hong Kong and expert in Pillar Two regulations, shares his valuable insights. He highlights the uneven implementation of Pillar Two across various Asia-Pacific jurisdictions and addresses the pending legislation in Hong Kong. Jesse explores the complexities of compliance management, particularly the pitfalls in transitional safe harbors and the unique challenges faced by industries like shipping and real estate. His crucial advice? Start preparing for compliance now!

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.

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Jenny Chong, Shanghai-based International Tax Partner and PwC’s Asia-Pacific International Tax Services Leader. Doug and Jenny discuss the structure and enforcement of China’s international tax regime, including corporate tax rates, incentives, CFC rules, and foreign tax credits. They examine the complexities of indirect stock transfer rules, audit trends, and beneficial ownership requirements. The conversation turns to Pillar Two, where Jenny outlines how Chinese multinationals are preparing despite a lack of formal adoption. They also explore the implications of potential termination of the US-China tax treaty and the resurgence of tariffs. Jenny shares how Chinese companies are adapting to compliance burdens and regulatory uncertainty amidst global tax and trade tensions. 

Doug McHoney chats with Leo Johnson, a lecturer at Oxford and co-founder of Sustainable Finance, known for his insights on megatrends. They delve into the psychological hurdles tax professionals face during crises, like climate change and economic stress. Leo introduces behavioral personas such as catalysts and silent rebels and discusses strategies to overcome resistance to change. Together, they emphasize the importance of purpose, autonomy, and collaboration in fostering high-performing teams while addressing burnout and cultivating meaningful work.