Cross-border Tax Talks

Doug McHoney (PwC’s International Tax Services Global Leader) is with Pat Brown, Washington National Tax Services Co-Leader, to discuss the complex state of international tax today and where the winds of Pillar Two are blowing. Doug and Pat bare their ankles and kick off the discussion with the state of international tax when Pat graduated law school.  They cover the increasing complexity of tax regimes, before diving into Pillar Two, the Undertaxed Payments Rule (UTPR), qualified CbC reporting, business concerns and struggles, the United Nations’ role in international tax, and recently published Belgian Pillar Two registration requirements. 

Doug McHoney (PwC's Global International Tax Services Leader) and Peter Reilly (PwC International Tax Partner & Ireland’s Tax Policy Leader) are at PwC EMEA’s International Tax Academy in Prague to discuss Ireland’s implementation of Pillar Two. Doug and Peter dive into why Irish policy makers agreed to adopt the Pillar Two regime, how Ireland is incorporating the OECD guidance, the potential effects on the Irish economy and current tax regime, the ways Irish multinationals are preparing, and the potential ramifications in the future. 

Doug McHoney (PwC's Global International Tax Services Leader) and podcast regular Calum Dewar (Principal, International tax services) are at PwC’s EMEA’s International Tax, Legal, and Workforce Academy in Prague, Czech Republic, to discuss the latest happenings around Pillar Two. Doug and Calum examine the many practical issues taxpayers, governments and tax advisors are facing to implement the new rules, including disparity in financial accounting, the QDMTT safe harbour, arbitrage arrangements, GloBE reorganization rules, and allocation of deferred taxes.

Doug McHoney (PwC's US International Tax Services Global Leader) is with Anthony Sciarra, a Principal in PwC’s Tax Reporting and Strategy Practice and the Global Pillar Two Data Strategy leader, to discuss the importance of a Pillar Two Data Strategy. Doug and Anthony detail what taxpayers should be doing today to stay ahead of Pillar Two’s complexity, specifically highlighting: data sourcing, data forecasting, qualifying for the CbC Transitional Safe Harbor, considerations for both an insourcing & outsourcing model, existing technology solutions, and the importance of a centralized rules calculation. 

Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s International Tax Conference in Dana Point, California with Dr. Alexis Crow, PwC’s Geopolitical Investing Practice Leader. Doug and Alexis discuss the recession outlook and economic activity, the impact of inflation, central banking policy, including interest rates, commercial real estate and financial stability, currencies and the future of the US Dollar, energy transition, the US election outlook, and outlooks for some significant economies, including Japan, India, Singapore, Brazil, the Middle East, and Europe.

Doug McHoney (PwC’s International Tax Services Global Leader) is in São Paulo, Brazil for the first Latin American recording of the CBTT with PwC Brazil’s International Tax Leader Dr. Romero Tavares. Doug and Romero discuss what makes Brazil’s tax system so unique – from its transfer pricing rules to its full inclusion regime. They also dive into expected Brazilian tax changes, the many acronyms that make up the indirect tax system, Pillar One, and what effect Pillar Two will have on Brazil’s taxpayers.

Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s International Tax Conference in Dana Point, California with former House Ways & Means Chairman Dave Camp, now senior policy advisor in PwC’s Washington National Tax Services. Doug and Chairman Camp discuss his political career, drivers behind US tax policy, how Congress negotiates tax legislation, the expiring provisions in the Tax Cuts & Jobs Act (TCJA), the prospects of Congress implementing Pillar Two in the years ahead, and how companies can get involved in the tax legislative process.

In this episode of Cross-Border Tax Talks, Doug McHoney interviews Craig Stronberg, a Senior Director in PwC's Intelligence Team, about major geopolitical trends impacting business leaders and the operating environment. They discuss topics such as protectionism, the US-China rivalry, distrust, the shift in global power, tech disruption, labor, and the Middle East. They also highlight the importance of business leaders taking stock of lessons learned from the COVID-19 pandemic and the potential risks associated with the ongoing conflict in Ukraine.  

On this episode, Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Wade Sutton. Wade is PwC’s Washington National Tax Service’s ITS Leader, a former adjunct professor of international tax at Georgetown University's Law Center, and former Deputy International Tax Counsel, US Treasury. Doug and Wade discuss what drove them to international tax as a career (spoiler: job security) before diving into recent US tax guidance. They discuss the recent foreign tax credit (FTC), corporate alternative minimum tax (CAMT) and Previously taxed E&P (PTEP) notices. They also discuss the interaction of Pillar Two with the FTC rules, dual consolidated loss (DCL) rules, and CAMT. Doug and Wade wrap up by looking ahead to guidance we might see in 2024. 

In this podcast episode, Doug McHoney, PwC’s International Tax Services Global Leader, interviews Heather Horn, PwC's Assurance National Thought Leader and host of the twice-weekly PwC Accounting Podcast. Doug and Heather discuss sustainability reporting and its increasing importance in the business world. They cover various regulations and standards, such as the EU’s Corporate Sustainability Reporting Directive (CSRD), and the potential intersection between sustainability reporting and tax transparency. Doug and Heather note the similarities between CSRD and other recent reporting requirements, like Pillar Two and the EU’s Foreign Subsidies Regulation (FSR). They also highlight the challenges and considerations for companies as they deal with new stakeholders and navigate the new reporting requirements.