Merging lanes: key MA and international tax considerations after TCJA

Doug McHoney (PwC's US International Tax Services Leader) and Mark Boyer (a Partner in PwC's Washington National Tax MA practice) discuss key MA and international tax considerations after the Tax Cuts and Jobs Act (TJCA). Doug and Mark discuss: life at the IRS before, during, and after the 1986 Tax Reform Act; top diligence concerns in MA transactions post-TCJA; how acquisitions unintentionally may subject companies to the Base Erosion and Anti-Abuse tax (BEAT); key structuring considerations post-TCJA, including the concept of a 'worldwide system of taxation' through BEAT, Foreign Derived Intangible Income (FDII), and global tax reform; the importance of modeling and data accuracy for tax and transaction planning; and the differences between strategic buyers and private equity.