Doug McHoney (PwC's US International Tax Services (ITS) Leader) is live at the Westminster Studios with Tom Patten (ITS Partner based in London) to discuss current and future tax considerations for US inbound companies. Doug and Tom chew on toasted ravioli and sandwich structures and then cover, among other topics: the impact of a Pillar 2 regime on US inbound companies; the potential for replacing the base erosion anti-abuse tax (BEAT) with the Stopping Harmful Inversions and Ending Low-tax Developments (SHIELD) provision, impending changes and proposals to interest expense, further limiting the ability of domestic corporations to expatriate; the effects of Brexit on US inbounds; and the potential for Pillar 1 to spurn treaty negotiation and ratification.