Cross-border Tax Talks

Doug McHoney, PwC’s International Tax Services Global Leader, teams up with Janice Mays, a veteran of tax policy with 40 years in government. Together, they dissect how the upcoming U.S. elections could reshape tax policy. They discuss key Senate and House races to watch, explore bipartisan challenges in tax reform, and examine the potential effects of election outcomes on corporate tax rates. The conversation also tackles the complexities of the GUILTY proposal and its implications for corporate adaptation amidst shifting political dynamics.

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Wade Sutton, International Tax Leader for PwC’s Washington National Tax Practice. Doug and Wade kick off with the persona of a law school professor, providing an overall perspective on the US common law system, and how the US court system works.  They then cover the importance three of Supreme Court’s recent tax case decisions – Moore v. United States, Corner Post v. United States, & Loper Bright v. United States. They start by ‘briefing’ the cases before noting why taxpayers should pay attention to each case. Additionally, they cover a potential wealth tax, the possible effects of the cases on litigation and tax controversy, what constituted the majority opinion in Loper Bright, the overruling of the Chevron doctrine, and regulatory validity.  

Doug McHoney and Phil Ramstetter discuss OECD's Admin Guidance on Pillar 2, focusing on DTL recapture rule, cross-border tax allocation, GloBE rules, entity classification, and more. They highlight challenges in simplifying tax rules, global accounting, and enacting OECD guidance into national laws.

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Nita Asher, International Tax Partner in PwC’s Washington National Tax Practice and former legislative counsel to the Joint Committee of Taxation during the enactment of TCJA in 2017. Doug and Nita focus on the Stock Buyback Excise Tax enacted under the Inflation Reduction Act. Doug and Nita walk through Notice 2023-2, the recently released procedural and technical regulations, including the elimination of the per se rule, the funding rule, and which other countries are considering similar rules. They also discuss how the excise tax could present a multi-year reporting exercise for taxpayers, utilizing Forms 720 and 7208. Non-US headquartered companies will be very interested in this conversation!

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.