Tax Audiocasts

For foreign banking and capital markets groups with U.S. operations, the OECD’s side-by-side framework introduces a distinct set of considerations under Pillar 2. In this episode, Denise Schwieger and Chris Riffle examine the inbound perspective, including how the framework may apply differently to U.S. branches and subsidiaries and why the ultimate parent entity’s home jurisdiction is a critical starting point for determining potential side-by-side relief.

The discussion also explores the treatment of branch profits tax, FDAP withholding and treaty-reduced rates within Pillar 2 effective tax rate calculations. For inbound tax leaders, the key is understanding how the group’s U.S. operating structure, income flows and treaty positions interact with both side-by-side and ongoing Pillar 2 compliance requirements. 

Digital asset taxation is entering a new phase of legislative activity, and for banking and capital markets organizations, understanding these proposed changes will be critical to staying ahead of compliance and reporting obligations. In this episode, Denise Schwieger and Mazhar Wani unpack the House Ways and Means Committee's June 2026 legislative package aimed at modernizing digital asset tax rules.

“Tax alpha” is widely used across the market and can be defined in different ways — its value depends on how you measure it and who the investor is. Learn more in Episode 1 of PwC's Tax Alpha audiocast series.

Tax-aware funds pursue after-tax benefits through levered long/short and 150/50 fund approaches and ordinary loss strategies. Learn more in Episode 2 of PwC's Tax Alpha audiocast series.

Wash sales, straddle rules, allocations, and investor-level limits can materially affect whether benefits are actually usable. Learn more in Episode 3 of PwC's Tax Alpha audiocast series.

Emerging structures, combined strategies, and tech/AI-enabled execution are accelerating innovation amid evolving regulatory attention. Learn more in Episode 4 of PwC's Tax Alpha audiocast series.

States are increasingly turning to high-income and high-net-worth individuals as a source of new revenue, but what looks like a simple rate hike often carries far more complex consequences. In this episode, Brian Rebhun, PwC’s Financial Services Tax Leader, and Ben Muilenburg, PwC’s State and Local Tax Partner, break down the rising wave of millionaire taxes, billionaire surcharges, and wealth tax proposals in states like California, New York, Massachusetts, and Maryland, and explore why these measures may involve more than the headline rate change.  

Opportunity zones continue to develop as a strategic tool for family offices focused on long-term wealth preservation and purposeful investing. In this episode of PwC’s Financial Services Tax Audiocast series, Jonathan Flack, PwC’s Global and US Family Office Leader, and Steve Kennedy, PwC’s National Opportunity Zone Specialist, discuss the latest changes under OZ 2.0 — including new timing flexibility, expanded benefits, tighter zone designations, and increased compliance requirements — and highlight the importance of early planning and careful structuring.

Corporate tax rules for charitable contributions are changing, and for banking and capital markets organizations, how and when contributions are made will matter more than ever. In this episode, Denise Schwieger and Monic Kechik unpack the introduction of a new 1% floor on deductible charitable contributions and what it could mean for  financial institutions with established giving programs, exploring how the new tax threshold interacts with community investment strategies and why organizations may need to reassess contribution timing, structures, classification, and financial reporting as they adapt to the evolving tax rules. 

Global minimum tax rules continue to evolve, and for banking and capital markets organizations, regulatory design matters. In this episode, Denise Schwieger and Chris Riffle unpack the OECD’s newly released side-by-side system under Pillar Two and what it could mean for US-parented banks, broker-dealers, asset managers and capital markets groups. The discussion explores how the new framework interacts with highly regulated legal-entity structures, why recent OECD determinations are notable for US groups, and how tax leaders can balance near-term compliance with longer-term simplification opportunities as the rules take shape.