Cross-border Tax Talks

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.

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.

In this engaging discussion, Dom Megna, a New York-based tax partner at PwC, dives into the transformative role of AI in tax practices. He clarifies key concepts like generative AI, machine learning, and deep learning. The conversation highlights how AI can enhance data management and streamline documentation, emphasizing the need for human oversight. Dom also reflects on the evolving roles of tax professionals and the importance of responsible AI use, exploring both opportunities and challenges in this new frontier.

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.

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.

Doug McHoney, PwC's International Tax Services Global Leader, and Will Morris, PwC's Global Tax Policy Leader, discuss the progress of Pillar Two. They explore the administration and adjudication process, potential FAQs and future guidance from the OECD, the recent EC guidance, retroactive OECD guidance implementation, and business participation in the process.

Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s Global Transfer Pricing Conference where he’s joined by Giorgia Maffini. Giorgia is part of PwC’s Global Transfer Pricing team in London and was previously the Deputy Head of the Tax Policy and Statistics Division at the OECD. Doug and Giorgia discuss why taxpayers should care about Pillar One, starting with the basics - what is Pillar One and how does it work with Pillar Two? They discuss the complexities, scope and impacts of both Amount A and Amount B. Also the timing, economic impact, and what’s next. Finally, they address what might happen with digital services taxes and what companies should do next.