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.  

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Jesse Kavanaugh, an international tax partner at PwC Hong Kong who leads Tax Reporting & Strategy and co-heads PwC’s Asia-Pacific Pillar Two team. Formerly the global head of tax operations for a US tech multinational, Jesse brings both in-house and advisory insights. Doug and Jesse discuss the uneven rollout of Pillar Two across nine Asia-Pac jurisdictions; China, India and US uncertainties; Hong Kong’s Pillar Two legislation (pending when this podcast was recorded, but enacted on June 6, 2025) and HKMTT design; why many countries are shelving the UTPR; looming QDMTT deadlines; the critical difference between data-gathering and calculation engines; pitfalls that blow up transitional safe harbors, including management accounts, hybrid loans, interest-free debt and purchase-price accounting; and industry-specific challenges for shipping, airlines and real estate. Jesse closes with a simple message: start compliance prep now…registration and early QDMTT filings wait for no one. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined on June 24, 2025, by Pat Brown, an International Tax 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. Doug and Pat start where they left off discussing 'One Big Beautiful Bill' (OB3), in wake of the US Senate Finance Committee Chairman's Substitute Amendment. They discuss the next steps in the legislative timeline including the impending July 4th deadline, the impact of the Byrd rule, as well as the many changes to both the business and international provisions. They focus on the major changes to Section 899, global intangible low-taxed income (GILTI), foreign derived intangible income (FDII), and the base erosion and anti-abuse tax (BEAT).  

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. Pat previously served as the US Treasury’s Associate International Tax Counsel and has been a frequent guest on the podcast. Doug and Pat discuss the legislative and international tax implications of the 'One Big Beautiful Bill', including its procedural path through US Congress under budget reconciliation, and its implications for both domestic and cross-border taxpayers. They explore the bill’s temporary business provisions, including TCJA 'orphan' fixes, and the evolving treatment of research expenses, bonus depreciation, and interest deductions. A major focus is Section 899—dubbed the 'super BEAT'—which targets foreign digital services taxes (DSTs), diverted profits taxes (DPTs), and Pillar Two’s undertaxed profits rule (UTPR) with steep retaliatory measures. They also analyze the international negotiations around UTPR exemptions, the impact on treaty obligations, and the ongoing debate over treatment of US tax credits—particularly the R&D credit—under global minimum tax rules. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Jenny Chong, Shanghai-based International Tax Partner and PwC’s Asia-Pacific International Tax Services Leader. Doug and Jenny discuss the structure and enforcement of China’s international tax regime, including corporate tax rates, incentives, CFC rules, and foreign tax credits. They examine the complexities of indirect stock transfer rules, audit trends, and beneficial ownership requirements. The conversation turns to Pillar Two, where Jenny outlines how Chinese multinationals are preparing despite a lack of formal adoption. They also explore the implications of potential termination of the US-China tax treaty and the resurgence of tariffs. Jenny shares how Chinese companies are adapting to compliance burdens and regulatory uncertainty amidst global tax and trade tensions. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Leo Johnson, lecturer at Oxford University’s Smith School of Enterprise and the Environment. Leo is also co-founder of the advisory firm Sustainable Finance, where he chairs the Advisory Council, and previously worked at the World Bank. Known for presenting the BBC series on megatrends and innovation. Leo brings unique insight into organizational behavior, neuroscience, and purposeful leadership. 

Doug and Leo discuss organizational inertia, transformation resistance, and how neuroscience and behavioral science explain our resistance to change—even amid crises like climate change, geopolitical turmoil, and economic stress. They explore how professionals, including those in international tax, can overcome ‘learned helplessness’ and avoid burnout by embracing purpose, agency, and connectedness. Leo introduces the concept of behavioral personas within organizations—catalysts, silent rebels, workhorses, and sustaining innovators—and emphasizes the need for authentic engagement and collaboration to drive meaningful change.