Cross-border Tax Talks

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. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Chris Desmond, PwC’s US Global Trade Services Leader to catch up on the latest customs and trade happenings. Doug and Chris talk about Chris’s transition from a transfer pricing partner to specializing in customs and trade, the potential US tariffs environment post election, how companies might respond with supply chain changes, the impact of the recent Mexican and Canadian tariffs, the use of tariffs as a retaliatory action, how tax authorities are leveraging customs data, as well as the importance of modeling, documentation, and data gathering. 

Steve Kohart, an International Tax Partner at PwC and former OECD advisor, shares valuable insights into the complexities of Pillar Two in international taxation. He discusses the Qualified Domestic Minimum Top-Up Tax (QDMTT) and the global implications for multinationals, particularly in Puerto Rico. The conversation delves into challenges around year-end compliance and data readiness, as well as pitfalls like hybrid arbitrage and financial statement finalization. Kohart also clarifies the concept of a 'good' credit under these new regulations.

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by returning guest Aaron Junge, an International Tax Partner in PwC’s Washington National Tax Services Practice. Aaron served as Tax Counsel to the US House of Representative during the passing of the Tax Cuts and Jobs Act in 2017. Doug and Aaron briefly discuss the College World Series held in Aaron’s hometown of Omaha, before delving into the Corporate Alternative Minimum Tax (CAMT) proposed regulations. Specifically, they discuss Adjusted Financial Statement Income (AFSI), how the rules affect large domestic and foreign investment funds and partnerships, the open comment period, the similarities (and differences) between CAMT and Pillar Two, whether or not CAMT could be converted to a QDMTT, how the regulations impact adjustments for depreciation, and new foreign stock rules.  

In this engaging discussion, Alex Voloshko, an International Tax Partner specializing in value chain transformation, joins Doug McHoney to explore the intersection of taxation and business strategies. They delve into how technological advancements are reshaping business models and the significant tax implications of shifting to service-oriented, recurring revenue models. The conversation also highlights the tax challenges arising from geopolitical complexities in supply chains and the impact of Pillar Two's minimum tax on global investment strategies. A must-listen for navigating today's tax landscape!

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by returning guest Elizabeth Nelson, a Partner in PwC’s Washington National Tax Services Practice to discuss the recently proposed regulations that address dual consolidated loss (DCL) rules as well an entirely new tax regime regarding disregarded payment losses (DPLs). Together they dive into the background of the US DCL rules, effective dates, foreign use, intercompany transactions, stock inclusions, mirror legislation, a new anti-avoidance rule, and of course the application of the DCL rules to Pillar Two.   

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by returning guest Rebecca Lee, a Principal in PwC’s Washington National Tax Services Practice where she focuses on complex tax problems and financial transactions in the digital asset space. Doug and Rebecca discuss T.D. 10000, the recently published final regulations dealing with digital assets. They dive into the details of digital assets, including the definition of a digital assets, revisiting non-fungible tokens (NFTs) and blockchain, and the different types of digital transactions. They also cover the background of the final regulations, calculating gains and losses, determining basis, digital asset transaction costs, ordering rules, Form 1099-DA, Notices 2024-56 & 2024-57, and the applicability dates. They finish the podcast with an exploration of how other jurisdictions are approaching cryptocurrencies around the world, touching on FATCA, DAC8 and more.