Cross-border Tax Talks

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.

Doug 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 the OECD’s Pillar One and Two, as well as how the new administration could approach digital services taxes (DSTs).

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 (QDMTT) return, the interaction of the Belgium patent box regime with Pilar Two, and the constitutionality of the Undertaxed Profits Rule (UTPR), among other topics.