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© 2025 Cross-border Tax Talks
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PwC specialists share insights and perspectives on key issues impacting the ever-changing tax landscape. Our podcasts aim to provide quick, easy and up-to-date tax developments to help you stay current and competitive in today's challenging business environment. Listen to episodes at your convenience via your desktop computer or smart device.
168 Episodes
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Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Will Morris, PwC’s Global Tax Policy Leader and former Director of Global Tax Policy at General Electric to look ahead to potential global tax policy changes. Will enlightens Doug about the confluence of tax and tariffs, digital services taxes (DSTs), the importance of communicating with the C-suite, the fate of Pillar Two, how the undertaxed profits rule (UTPR) could change, the role of the UN and global tax, and the ...
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Andy Wiggins, PwC Partner based in the United Kingdom and PwC’s Global Tax Accounting Services Leader to(birming)ham it up on the tax accounting implications of Pillar Two. Together they discuss, deferred accounting, the differences between US Generally Accepted Accounting Principles (GAAP) and International Financial Reporting Standards (IFRS), accounting implications of the qualified domestic minimum top-up tax (QDMT...
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 retroact...
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Stewart Brant, Managing Director in PwC’s Tax Policy Services to discuss the latest Pillar Two developments. Doug and Stewart start off – after baseball of course – discussing the purpose of the Digital Tax Study Group. Then they cover the status of Pillar Two enactment in Europe, Asia, the Americas, the Pacific, the Caribbean, Middle East, and Africa. They also cover how different countries are applying the rules retr...
1Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Rohit Kumar, PwC’s National Tax Co-leader and former deputy chief of staff to Senator Mitch McConnell (R) to discuss the US election results. Doug and Rohit cover what the republican-controlled House, Senate and Presidency means for tax reform, why 2025 will be a year for significant “must-pass” tax legislation, the role the federal debt and budget deficit will play, the potential implementation of tariffs, the fate of...
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 (QD...
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 ...
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by returning guest Steve Kohart, an International Tax Partner in PwC’s New York City office and former advisor to the Center for Tax Policy Administration for the OECD. They dive into Pillar Two with a refresher of the Qualified Domestic Minimum Top-up Tax (QDMTT), the Income Inclusion Rule (IIR), the Under Tax Profit Rule (UTPR), as well as the status of Pillar Two enaction across the globe, including in Puerto Rico. The...
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, t...
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by returning guest Alex Voloshko, an International Tax Partner in PwC’s Washington National Tax Services Practice where he specializes in value chain transformation and the tax implications of business operating models. Doug and Alex discuss how tax interacts with the broader business, the evolution of the tax operating model, business model reinvention, the importance of data, supply chain management, IP trends from the ...
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,...
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 (NF...
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Janice Mays (Managing Director in PwC’s Tax Policy Services) who boasts a 40 year career on the Hill including 22 years as the Democratic chief counsel and staff director for the House Ways and Means Committee, to discuss the upcoming US election’s impact on tax policy. Doug and Janice dive into the practice and procedures behind US tax policy, the upcoming US presidential election, and the key races to wat...
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 Sta...
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Phil Ramstetter, International Tax Partner and former Tax Policy Consultant at Business at OECD (BIAC). Doug and Phil discuss the OECD’s Administrative Guidance released in June 2024, including the deferred tax liability (DTL) recapture rule or five-year rule, the allocation of cross-border taxes, deferred tax accounting, transactions within the GloBE rules, entity classification and treatment, and the expectation of m...
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 r...
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 re...
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,...
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 arrangeme...
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 insour...
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