Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Kristin Bohl, a Partner in PwC’s Customs and International Trade Practice. Kristin previously served as a judicial law clerk at the U.S. Court of International Trade. Doug and Kristin discuss the rapidly evolving trade and tariff landscape, focusing on the recent executive orders imposing new tariffs on Canada, Mexico, and China under the ‘America First’ trade policy. They break down the impact of tariffs on industries such as automotive, pharmaceuticals, retail, and technology, and cover strategies that businesses can deploy to mitigate costs. Key topics include the authority of the US President to impose tariffs, the role of trade deficits in tariff policy, and the use of tariffs as a foreign policy tool. They also explore potential retaliatory measures from US trading partners, the impact on global supply chains, and short to long-term strategies for businesses to adapt to the new tariff regime. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Pat Brown, an International Tax Partner and Co-Leader of PwC’s Washington National Tax Services practice. Together, they unpack the state of US corporate tax policy in 2025, analyzing how regulatory, legislative, and geopolitical forces could shape the next era of taxation. Doug and Pat dissect the final regulations issued in the closing days of the Biden administration, including the controversial disregarded payment loss (DPL) regulations, finalized and proposed digital content and cloud sourcing rules, and updates on corporate basis-shifting transactions. With a new administration in power, they explore whether these rules will stand, be modified, or be repealed entirely—and what this means for business certainty and planning. The conversation then pivots to legislative challenges, as the expiration of key provisions from the 2017 Tax Cuts and Jobs Act (TCJA) creates a ticking time bomb for tax policy.  Finally, they tackle the international tax front, where the US f administration responds to the OECD’s Pillar Two and potential digital services tax (DST) retaliation under new proposals like Section 899.  

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Steve Kohart, an International Tax Principal in PwC’s New York City office and former advisor to the OECD’s Center for Tax Policy and Administration. Doug and Steve discuss the OECD’s latest administrative guidance on Pillar Two, covering key changes to transition rules, deferred tax asset adjustments, tax credits, and compliance burdens for multinational corporations. They dive into the OECD’s focus on Bermuda and Switzerland, new anti-abuse measures, implications of the Qualified Domestic Minimum Top-up Tax (QDMTT), and the complexities of the new Globe Information Return (GIR). The conversation also explores the political and procedural challenges in implementing additional guidance, particularly in light of the new US administration’s stance on Pillar Two. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Rebecca Lee, an International Tax Principal in PwC’s Washington National Tax Services practice. Rebecca specializes in financial transactions and digital assets and is one of the most frequent guests on the podcast. Doug and Rebecca discuss the long-awaited final and proposed regulations under Section 987, which deal with foreign currency gain or loss for qualified business units (QBUs). They dive into key topics, including methods for calculating 987 gains and losses, the transition rules, applicability dates, and the implications of different election options. They also cover major changes from the proposed to final regulations, including adjustments to the treatment of Section 988 transactions within a QBU, tax accounting considerations, the controversial suspended loss rules, and how partnerships are impacted.  

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Tadd Fowler, Senior Vice President Treasurer and Global Taxes of Procter & Gamble. With nearly two decades at P&G, Tadd shares insights from his dual leadership in tax and treasury. Doug and Tadd discuss P&G’s approach to tax certainty, compliance in over 180 jurisdictions, and the strategic benefits of operating on a single ERP platform. They delve into US tax policy, the impacts of the Tax Cuts and Jobs Act, and P&G’s commitment to transparency and tax advocacy. Additional topics include preparing for Pillar Two compliance, managing ESG taxation, and adapting to evolving global tax landscapes.  See P&G’s Approach to Tax. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Laura Williams, an International Tax Principal at PwC’s Washington National Tax Services office. Laura previously worked as the International Branch Chief at the IRS Office of Chief Counsel. Doug and Laura discuss the long awaited previously taxed earnings and profits (PTEP) proposed regulations. Together they walk through the core aspects of the PTEP regime, including PTEP accounting, increases and decreases to basis of stock and other property, foreign currency gain or loss, allocation of foreign tax credits, 'covered distributions’, US consolidated group rules, and the anti-avoidance rule. See our PwC Tax Insight for more details. 

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 potential for a US legislation as a reaction to DSTs and the UTPR. 

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 (QDMTT), income inclusion rule (IIR), and undertaxed profits rule (UTPR), country by country reporting (CbCR), and transitioning from the full safe habor to GloBe rules. 

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. 

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 retroactively, the impact a Trump administration could have on Pillar Two, as well as what role the UN could play.