Cross-border Tax Talks

Doug McHoney (PwC’s International Tax Services Global Leader) is with Pat Brown, Washington National Tax Services Co-Leader, to discuss the complex state of international tax today and where the winds of Pillar Two are blowing. Doug and Pat bare their ankles and kick off the discussion with the state of international tax when Pat graduated law school.  They cover the increasing complexity of tax regimes, before diving into Pillar Two, the Undertaxed Payments Rule (UTPR), qualified CbC reporting, business concerns and struggles, the United Nations’ role in international tax, and recently published Belgian Pillar Two registration requirements. 

Doug McHoney (PwC's Global International Tax Services Leader) and Peter Reilly (PwC International Tax Partner & Ireland’s Tax Policy Leader) are at PwC EMEA’s International Tax Academy in Prague to discuss Ireland’s implementation of Pillar Two. Doug and Peter dive into why Irish policy makers agreed to adopt the Pillar Two regime, how Ireland is incorporating the OECD guidance, the potential effects on the Irish economy and current tax regime, the ways Irish multinationals are preparing, and the potential ramifications in the future. 

Doug McHoney (PwC's Global International Tax Services Leader) and podcast regular Calum Dewar (Principal, International tax services) are at PwC’s EMEA’s International Tax, Legal, and Workforce Academy in Prague, Czech Republic, to discuss the latest happenings around Pillar Two. Doug and Calum examine the many practical issues taxpayers, governments and tax advisors are facing to implement the new rules, including disparity in financial accounting, the QDMTT safe harbour, arbitrage arrangements, GloBE reorganization rules, and allocation of deferred taxes.

Doug McHoney (PwC's US International Tax Services Global Leader) is with Anthony Sciarra, a Principal in PwC’s Tax Reporting and Strategy Practice and the Global Pillar Two Data Strategy leader, to discuss the importance of a Pillar Two Data Strategy. Doug and Anthony detail what taxpayers should be doing today to stay ahead of Pillar Two’s complexity, specifically highlighting: data sourcing, data forecasting, qualifying for the CbC Transitional Safe Harbor, considerations for both an insourcing & outsourcing model, existing technology solutions, and the importance of a centralized rules calculation. 

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.

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.

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.

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.

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.

Heather Horn, PwC's Assurance National Thought Leader and host of the PwC Accounting Podcast, joins Doug McHoney to dive into the rising importance of sustainability reporting. They discuss the EU’s Corporate Sustainability Reporting Directive and its implications for businesses. The conversation highlights the challenges in navigating new compliance demands while maintaining confidentiality. Horn emphasizes the crucial link between tax transparency and sustainability, calling for greater collaboration between tax and sustainability teams to adapt to evolving regulations.