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Cross-border Tax Talks

Latest episodes

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17 snips
Apr 10, 2024 • 35min

As the world turns: Macroeconomic trends

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.
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Mar 26, 2024 • 44min

Brazil Tax Reforms: muito complicado!

Doug McHoney (PwC’s International Tax Services Global Leader) is in São Paulo, Brazil for the first Latin American recording of the CBTT with PwC Brazil’s International Tax Leader Dr. Romero Tavares. Doug and Romero discuss what makes Brazil’s tax system so unique – from its transfer pricing rules to its full inclusion regime. They also dive into expected Brazilian tax changes, the many acronyms that make up the indirect tax system, Pillar One, and what effect Pillar Two will have on Brazil’s taxpayers.
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Mar 14, 2024 • 41min

US Tax Policy: Chairman Dave Camp

Former House Ways & Means Chairman Dave Camp shares insights on US tax policy, negotiations in Congress, expiring provisions in TCJA, and prospects of implementing Pillar Two. He emphasizes the importance of tax competitiveness, economic growth, job creation, and addressing the national debt. The discussion also touches on the challenges of passing tax legislation in the Senate, navigating international tax negotiations, and the role of American corporations in shaping tax policies.
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Feb 28, 2024 • 47min

Geopolitics Unraveled: Trends for 2024

Geopolitical trends impacting business leaders discussed, including protectionism, US-China rivalry, shift in global power, tech disruption, and Middle East. Importance of learning from COVID-19 and risks of Ukraine conflict highlighted.
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23 snips
Feb 13, 2024 • 47min

US Guidance Update: Pillar Two and more

Wade Sutton, PwC's Washington National Tax Service's ITS Leader, and Doug McHoney discuss recent US tax guidance including foreign tax credit, corporate alternative minimum tax, and previously taxed E&P notices. They also explore the interaction of Pillar Two with FTC rules and CAMT, while looking ahead to potential guidance in 2024.
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Feb 6, 2024 • 34min

Sustainability and Transparency for Tax Professionals

In this podcast episode, Doug McHoney, PwC’s International Tax Services Global Leader, interviews Heather Horn, PwC's Assurance National Thought Leader and host of the twice-weekly PwC Accounting Podcast. Doug and Heather discuss sustainability reporting and its increasing importance in the business world. They cover various regulations and standards, such as the EU’s Corporate Sustainability Reporting Directive (CSRD), and the potential intersection between sustainability reporting and tax transparency. Doug and Heather note the similarities between CSRD and other recent reporting requirements, like Pillar Two and the EU’s Foreign Subsidies Regulation (FSR). They also highlight the challenges and considerations for companies as they deal with new stakeholders and navigate the new reporting requirements. 
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4 snips
Jan 24, 2024 • 46min

Pillar Two: how safe is the safe harbor?

Steve Kohart, PwC international tax partner and former OECD adviser, joins Doug McHoney to discuss the OECD's Pillar Two Administrative Guidance. They cover topics like safe harbor implementation, purchase price adjustments, hybrid arbitrage arrangements, CFC tax allocation, and potential additional guidance in 2024.
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Jan 4, 2024 • 38min

Gen AI in Tax: a new frontier

Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s Tax Leadership Conference in breezy Orlando with Dom Megna, a New York-based tax partner leading PWC's US Tax Reporting and Strategy Practice. Doug and Dom discuss Artificial Intelligence (AI) and its place in tax. They focus on four areas - what is conversational AI, machine learning, deep learning, and generative AI (a subset of deep learning). They also cover some impacts of AI: AI for tax practitioners, how AI will affect people’s jobs, data opportunities and architecture, Pillar Two, responsible AI, and the ROI of AI. 
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21 snips
Dec 19, 2023 • 44min

Taxing FX of Branches: the new Section 987 regulations

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.
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4 snips
Dec 12, 2023 • 36min

UK Pillar Two: Painting while the paint dries

Matt Ryan, London-based international tax partner and PwC UK’s Pillar Two Leader, joins Doug McHoney to discuss the challenge UK legislators face in enacting legislation while the OECD guidance is still changing. They explore practical next steps for UK-parented taxpayers, complexities created by UK rules around safe harbors, and issues with partnerships and deferred taxes.

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