Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Tom Patten, a London-based US International Tax Partner at PwC. Tom focuses on inbound investment into the U.S. and returns to the podcast for a timely discussion on Sections 891 and 899, two lesser-known but increasingly important provisions in the international tax landscape.  Doug and Tom discuss the resurgence of Section 891 in light of a January 2025 executive order that directs Treasury to identify discriminatory or extraterritorial foreign taxes. They cover how Section 891 operates, potential implications for non-US citizens, and its interaction with treaties. The episode then turns to proposed Section 899 and a new House proposal aimed at modifying the base erosion and anti-abuse tax (BEAT). Tom and Doug examine how these retaliatory measures differ, overlap, and might evolve. They close with practical advice for multinational taxpayers navigating an uncertain legislative environment and the future of Pillar Two negotiations. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Dr. Romero Tavares, PwC Brazil’s International Tax Leader and a professor of international tax law in São Paulo. Doug and Romero discuss the increasing intersection between Brazil’s international tax policy and global trade dynamics, including the effects of recent US executive orders. They cover Brazil’s high-tax corporate environment, its historically aggressive CFC-like full inclusion regime, and the country’s rapid adoption of a qualified domestic minimum top-up tax (QDMTT). The conversation explores the political and policy rationale behind these moves, the anticipated redesign of Brazil’s CFC regime, and the operational challenges multinationals face with the new OECD-aligned transfer pricing rules. Romero also breaks down Brazil’s massive indirect tax reform and the country’s potential shift to more internationally-aligned tax norms, while questioning the long-term viability of the undertaxed profits rule (UTPR) and Pillar Two’s durability under changing geopolitical winds. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Dr. Alexis Crow, Partner and Chief Economist at PwC US. Before joining PwC, Dr. Crow taught at the London School of Economics. Doug and Alexis discuss the intersection of global macroeconomics, geopolitics, and international tax policy in a shifting global landscape. They break down the impact of the Trump administration’s latest tariffs on Canada and Mexico, inflationary pressures, interest rates, and the fiscal cliff facing the US. 

Doug and Alexis explore how the geopolitical climate is shaping international trade, the potential winners and losers of increased tariffs, and the broader economic implications of Trump 2.0. They also analyze regional macroeconomic trends, from China’s economic resilience and India's manufacturing rise to Europe's fiscal strategies and Latin America’s economic experiments. Lastly, they discuss how businesses—particularly multinationals—should be preparing for upcoming policy shifts and economic disruptions. 

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.