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Cross-border Tax Talks

Business & Economics Podcasts

PwC specialists share insights and perspectives on key issues impacting the ever-changing international tax landscape. Our podcasts aim to provide quick, easy and up-to-date international 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.

PwC specialists share insights and perspectives on key issues impacting the ever-changing international tax landscape. Our podcasts aim to provide quick, easy and up-to-date international 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.

Location:

United States

Description:

PwC specialists share insights and perspectives on key issues impacting the ever-changing international tax landscape. Our podcasts aim to provide quick, easy and up-to-date international 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.

Language:

English


Episodes

100th Episode Special: The evolution of global structuring

6/22/2022
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Mike Urse, current International Tax Partner and former US International Tax Services Leader for the 100th episode of the Cross Border Tax Talks podcast. Doug and Mike discuss the changing world of international taxation, focusing on the current status of holding companies, finance companies, and Intangible property companies. Mike provides insights and analysis from almost 40 years of international tax experience and...

Duration:00:37:22

In the Clouds: Pillar 2 Operational Readiness

6/13/2022
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined in Washington D.C. by Dom Megna, Tax Partner and leader of PwC’s US Tax Reporting and Strategy practice. They discuss the latest on Pillar Two developments, GAAP considerations, Enterprise Resource Planning Systems, the Cloud, the future of data collection, and more.

Duration:00:40:00

Back to School: Mindy Herzfeld’s Pillar 2 insights

5/25/2022
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Mindy Herzfeld, professor of tax practice at the University of Florida Levin College of Law, where she teaches International Tax, to discuss Pillar Two rules.

Duration:00:46:55

Green Book Proposals: Codifying Pillar 2 in the US?

5/9/2022
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Pat Brown, PwC’s International Tax Policy Leader, making his sixth appearance on the podcast. Doug and Pat discuss the Biden Administration's fiscal year 2023 budget proposals as explained in the Green Book, how some of the proposals interact with the OECD’s Pillar Two Model Rules, and what taxpayers might expect.

Duration:00:45:05

Pillar 2 Commentary: A knowledge GAAP?

4/27/2022
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by PwC’s Calum Dewar, Leader of PwC’s Integrated Global Structuring practice. They discuss the Pillar Two Model Rules & Commentary and its potential impacts on the global tax system, transfer pricing adjustments, deals and more.

Duration:00:50:45

Spin the Globe Macroeconomic and Geopolitical trends

4/6/2022
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by PwC’s Dr. Alexis Crow, PwC’s Geopolitical Investing Practice Leader. They discuss macroeconomic trends, the geopolitical landscape, the inflationary environment, trade wars, global/economic impacts on various sectors,and much more.

Duration:00:39:51

Tax Readiness: New York sales tax developments - SaaS and information services (State and local tax perspective)

3/28/2022
Recent New York court rulings are changing the guidelines for business tax payers around information service, software as a service, and taxation of bundled and mixed offerings, In this episode, PwC professionals from the State and Local Tax practice analyze these recent rulings. Presenters: Jamie BrennerRob Morse

Duration:00:16:07

The Final FTC Regs: Credibility for Creditability?

3/24/2022
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by PwC’s Washington National Tax Services International Tax Leader Michael DiFronzo, former Deputy Associate Chief Tax Counsel International at the IRS. They discuss some of the practicalities of the creditability rules in the Final FTC regulations (see February 2022 CBTT episode with Wade Sutton for an overview of the regulations), particularly cost recovery, attribution requirements, an unintended incentive to offshore...

Duration:00:37:25

Whirlpool Appellate Decision: A new standard for subpart F?

3/9/2022
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by PwC Value Chain Transformation Specialist Tom Quinn. They discuss the Sixth Circuit Court of Appeals ruling to uphold the US Tax Court’s May 5, 2020 decision, and concluded that a CFC’s income ‘attributable to’ a branch, in this case a manufacturing branch, per se is foreign based company sales income (FBCSI) under the statute if a ‘substantial tax deferral effect’ is found. They specifically discuss the Maquilladora...

Duration:00:39:42

ATAD3 - impacting the financial services industry and more

2/23/2022
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Puneet Arora, PwC ITS Partner and PwC’s Financial Services Consulting leader. They discuss the latest EU anti-tax avoidance directive (ATAD3), diving into the details and impact it could have on the financial services industry; the importance of modeling for Pillar Two; and the G in ESG, governance.

Duration:00:43:42

Double taxation ahead? Parsing the final FTC regs

2/7/2022
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Wade Sutton, PwC ITS Partner in the Washington National Tax Practice office and former deputy international tax council at Treasury. They discuss the highly technical topics of the final foreign tax credit regulations, credibility of tax under Section 901, the definition of an income tax, DSTs, nonresident taxation, effective dates, digital services taxes, withholding taxes, nonresident capital gains taxes, Puerto...

Duration:00:40:23

All aboard! The Pillar Two train is leaving the OECD and EU stations

1/21/2022
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Calum Dewar, PwC ITS Partner and leader of PwC’s Integrated Global Structuring Practice, heading our Outbound, Inbound, and Value Chain Transformation teams. Doug and Calum discuss Pillar Two Model Rules, the OECD/G20’s Inclusive Framework, the EU Directive, and more specifically the Income Inclusion Rule, the Under Tax Payment Rule and how country-by-country GILTI and the new final FTC regulations could impact the...

Duration:00:57:29

Below the line: Getting tax a seat at the business table

1/5/2022
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined in PwC’s DC studio by Mohamed Kande, PwC Vice-Chair and US and Global Advisory Leader. They discuss the need for proactive and intentional mentorship; relationship building in the virtual environment; the three different types of transformation trending in the market; and how (and why) tax should get a seat at the business table.

Duration:00:45:13

Tax reform: Digging in, before building back

12/14/2021
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Jeff Endress, US Outbound Tax Practice leader. They discuss the House-passed Build Back Better (BBB) bill, delayed effective dates, Section 163(n), foreign tax credits, country-by-country, the complexity of global tax, Pillar Two, uncertainties in the deals market, and the future of tax reform.

Duration:00:42:27

Why International Tax? One professional's career journey

11/30/2021
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Ugo Alisiobi, ITS Partner, based in our New York Metro ITS practice, for Ugo’s first time in St. Louis. They discuss their paths to careers in international taxation; the struggles, joys, and rewards of being an international tax practitioner; being proactive and authentic in your career; imposter syndrome; finding - and being - a mentor; and working at PwC.

Duration:00:42:24

Cryptocurrency Trends: Blockchain goes mainstream

11/10/2021
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Rebecca Lee (PwC ITS Washington National Tax Partner), who specializes in cross-border financial transactions. They discuss trends in cryptocurrency, including ‘operation hidden treasure,’ taxation of cryptocurrency transactions, US tax reform, El Salvador’s adoption of Bitcoin as legal tender, blockchain in the insurance industry, Bitcoin as an exchange traded fund (ETF), the digitalization of trust, updates on non...

Duration:00:40:14

BEPS 2.0 Update: not IF but when

10/26/2021
Doug McHoney (PwC's US International Tax Services Co-Leader) is in PwC's brand new studio in Washington, DC with Will Morris (PwC’s Deputy Global Tax Policy Leader). Will also was appointed Chair to the American Chamber of Commerce to the European Union and Chair to the Business Industry Advisory Committee to the OECD. Doug and Will discuss the journey thus far to Pillar One and Pillar Two. They touch on, among other things, the future impacts on US-based multinational companies, what has...

Duration:00:48:37

Playing by House Rules: More analysis of the Ways & Means bil

10/8/2021
Doug McHoney (PwC's US International Tax Services Co-Leader) is back in Westminster Studios with Nita Asher (PwC International Tax Services Partner), who served as legislative council at the Joint Committee on Taxation from 2017 to 2018. Doug and Nita pick up from the previous podcast with Sherry Grabow, and discuss the legislative climate; covering, among other topics: the legislative process for tax reform, how this iteration of reform differs from 2017, granting of regulatory authority,...

Duration:00:26:52

Tax Reform 2.0: the House "Ways" in

9/20/2021
Doug McHoney (PwC's US International Tax Services Co-Leader) is live at the Westminster Studios with Sherry Grabow (PwC's US International Tax Services Co-Leader) to discuss the international tax provisions in the recently released ‘Chairman’s Mark’ from the House Ways and Means Committee. Doug and Sherry cover, among other topics: Interest expense under new Section 163(n) and existing Section 163(j); changes to foreign derived intangible income (FDII), modifications to the global intangible...

Duration:00:42:43

Tax Reform 2.0: Hot topics in inbound taxation

9/1/2021
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...

Duration:00:24:59