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.

Tax Reform 2.0:  Hot topics in inbound taxation

PwC specialists share insights and perspectives on key issues impacting the ever-changing tax landscape. Our podcasts aim to provide quick, easy and up-to-date tax developments to help you stay current and competitive in today's challenging business environment. Listen to episodes at your convenience via your desktop computer or smart device.

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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.

Pillar Two: Hindsight is 20/24

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.

Pillar Two Data Strategy: Play ball!!!

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.

As the world turns: Macroeconomic trends

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.

Brazil Tax Reforms: muito complicado!

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.

Tax Reform 2.0: Hot topics in inbound taxation

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