Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Pieter Dere, a partner in PwC Belgium’s International Tax Services practice who leads Belgium’s Pillar Two initiative and co‑hosts the Tax Bites Podcast. Doug and Pieter recorded in Prague at PwC’s Global Transfer Pricing, Customs, and Indirect Tax Conference. They discuss Belgium’s Pillar Two compliance landscape: 2024 applicability of QDMTT/IIR/UTPR, a late‑November 2025 filing cycle; the new e‑platform and XML‑only submissions; transitional safe harbors and JV scope; the ‘general representative’ and joint and several liability; DAC 9 and the OECD MCAA; uncertainty around a G7 side‑by‑side and implications for US‑parented groups; estimated payments; Belgian litigation targeting UTPR; and practical steps to be ready now. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Sarah Hickey, a PwC Australia International Tax Partner and the Australian tax desk leader in New York City. Doug and Sarah discuss Australia’s corporate tax landscape (30% headline rate; new thin-cap at 30% of tax EBITDA with a retrospective integrity rule on related‑party debt), investment incentives, the two‑speed CFC regime and “use it or lose it” foreign tax credits, and dividend, interest, and royalty withholding. They cover the diverted profits tax (40% rate; 12‑month evidence window), Pillar Two timing, public CbCR and short‑form restructure disclosures due by end‑2025, and indirect taxes including non‑resident CGT and stamp duty. Finally, they unpack the High Court’s Pepsi decision—no royalty derivation by the US, a 4–3 win on royalties and DPT—and why contract wording anchors royalty analyses. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Mitch Schuckman, who is retiring after 39 years at PwC and has held a range of leadership roles, most recently leading PwC’s Global Tax Pursuits. Mitch is also the author of “I’ll Tell You a Great Story” and is a certified professional coach. Doug and Mitch discuss the evolving nature of tax careers, from early technical work to client pursuits and leadership development. The conversation explores the importance of storytelling, the role of professional coaching, and the attributes of high-performing teams and individuals. Mitch shares insights on building trusted advisor relationships, the necessity of collecting diverse experiences, and the challenges and rewards of fostering strong team culture, especially in a post-pandemic, hybrid workplace. Mitch reflects on his career, the significance of mentorship, and his future plans in executive coaching and leadership development. 

Wade Sutton (PwC’s Washington National Tax Services - International Tax Services Leader) is joined by Pat Brown, an ITS Partner and Co-Leader of PwC’s Washington National Tax Services practice. Pat previously served as the US Treasury’s Associate International Tax Counsel and has been a frequent guest on the podcast. Wade and Pat take a deeper dive into the future of Pillar Two, focusing on the G7’s ‘side-by-side' agreement.  They highlight the historical positions of previous US administrations, why  proposed Section 899  was dropped from OBBBA, US dissatisfaction with the lack of accommodations for the US GILTI regime and R&D tax credits, the OECD process and how countries could implement changes, and the potential for simplification including a potential permanent safe harbor. Finally, they look to the future and what may happen next. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Wade Sutton, a principal who leads the international tax team in PwC’s Washington National Tax Services practice. Doug and Wade discuss OB-3’s outbound impacts and the ripple effects across the system: CAMT interactions and credit ordering; Section 174 R&E expensing elections; Section 163(j) excluding CFC items and the financing/on-lending response; FDII’s shift to FDDEI, a permanent 14% rate, and 2026 expense-apportionment relief; GILTI’s rebrand to Net CFC tested income with a 14% effective rate and ‘directly allocable’ expense questions; inventory-sourcing relief; repeal of the Section 898 one-month deferral; permanent CFC look-through; the Section 958(b)(4) fix; a new Section 951(a)(2)(B) framework; selected technical corrections; and why granular modeling matters now more than ever.  

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Nita Asher, an international tax principal in PwC’s Washington National Tax Services practice focused on inbound multinationals, with prior government experience during the TCJA. Doug and Nita discuss the One Big Beautiful Bill Act (“OB3”) and its impact on inbounds, including permanent 100% bonus depreciation; new Section 168N for qualified production property; Section 163(j)’s EBITDA-based ATI; the reworked ‘FDDEI’ (formerly FDII) and its 14% rate with outbound IP limits; shifting IRA credit timelines and ‘foreign entity of concern’ issues; BEAT’s modest rate bump to 10.5% and unchanged credit treatment; the potential future of Section 899; and CAMT interactions. Throughout, they emphasize modeling to avoid BEAT/CAMT whipsaws while capturing OBBBA cash-flow benefits.

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Raza Janjua, a Director in PwC’s ITS practice in New York and author of a recent article on Pillar Two hybrid arbitrage arrangements. Doug and Raza discuss the BEPS Action 2 origins and ATAD 2 implementation; how Pillar Two’s simplified safe harbors spawned detailed hybrid arbitrage rules; the core categories—deduction–non‑inclusion, duplicate loss, and duplicate tax recognition; real‑world traps like preferred equity treated as book debt, FX‑driven mismatches, valuation‑allowance hypotheticals, cash pools and back‑to‑backs; narrow dual‑inclusion relief and why it should be jurisdiction‑level; CFC‑regime interactions; retroactivity and early adoption; and what future administrative guidance and the G7 architecture could mean for US rules such as Sections 245A(e), 267A, and the DCL regime.  

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by returning guest Craig Stronberg, Senior Director of PwC Intelligence. Craig previously had a near 20-year career in National security affairs before joining PwC. Craig and Doug discuss changes to US global policy and protectionism; the rise of new global powers and alliances; the growing divide between developed and developing countries regarding global tax policy; the debate over globalization’s benefits; and the current trade environment. They also discuss how multinational companies are responding to uncertainty, deploying corporate risk management, scenario planning, and gaining competitive advantages. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Mike Urse and Calum Dewar, both retiring PwC International Tax partners with decades-long careers in cross-border tax. Mike served as PwC’s US ITS Leader, while Calum built his career across PwC UK and PwC US, specializing in European and global tax systems. Doug, Calum and Mike discuss the dynamic nature of international tax and the intellectual curiosity that drew them to the profession. They also reflect on the evolution of PwC’s international tax practice, consensus-driven leadership, and building high-performing teams. The trio shares stories on mentorship, the impact of technology - from dictaphones to AI - and how global tax reform has shaped the practice. With humor and candor, they offer career advice to current and future tax professionals and celebrate the relationships, challenges, and learning that have defined their time at PwC. 

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 and former US Treasury’s Associate International Tax Counsel. In part three of Doug’s three-part OBBBA discussion with Pat, they discuss the newly enacted OB3 reconciliation law, focusing on its permanent corporate and individual tax provisions, the recalibration of bonus depreciation, Section 174 expensing and Section 163(j); the Senate’s redesign of GILTI, FDII and BEAT; Inflation Reduction Act rollbacks; Treasury’s last-minute removal of Section 899; and the G7’s surprise accord intended to exempt US-parented groups from Pillar Two’s IIR and UTPR while elevating QDMTTs and compliance simplification. They map the procedural and legislative steps still needed, potential timing gaps, and why multinational groups must keep Pillar Two compliance front-of-mind.