Cross-border Tax Talks

Doug McHoney (PwC's International Tax Services Global Leader) is joined in Madrid by Arne Schnitger, International Tax Partner with PwC Berlin and host of the German podcast Frisch Serviert (Freshly Served). They dive into the German legislative process, compliance and reporting, the German QDMTT, deviations from the OECD Model Rules, as well as the interaction with the US GILTI regime. They also discuss Arne’s recent article, “Does the 'Initial Phase Relief' Make the EU’s Pillar Two Directive Invalid?

Doug McHoney (PwC's International Tax Services Global Leader) is joined in Madrid by Edwin Visser, PwC’s European Tax Policy Leader. Prior to joining PwC, Edwin was the Deputy Director General for Tax Customs Policy and Legislation and Director for Direct Taxes at the Dutch Ministry of Finance. One of the real challenges for tax professionals and advisors is the sheer volume of tax proposals from the European Union. Edwin and Doug discuss the numerous EU tax proposals, including the Carbon Border Adjustment Mechanism (CBAM), the Foreign Subsidies Regulation (FSR), Green Energy Credits, ATAD3. They also cover the EU’s legislative process, flashback to the Common Consolidated Corporate Tax Base (CCCTB), then tackle Business in Europe: Framework for Income Taxation (BEFIT), the SAFE project, and the Debt-equity bias reduction allowance (DEBRA). They cap the episode with a check in on Pillar One and Pillar Two.

Doug McHoney (PwC's US International Tax Services Global Leader) hosts Matt Ryan, London-based International Tax Partner and leader of PwC’s UK Pillar Two Ready Team. Doug and Matt discuss the second draft of the UK’s Pillar Two legislation, the probable timing of enactment, the accounting implications, the UK’s Qualified Domestic Minimum Top-up-Tax, and some of the ‘deviations’ in the UK rules.

Doug McHoney (PwC's US International Tax Services Global Leader) is joined by Pat Brown, seven-time veteran of the podcast, and co-leader of PwC’s WNTS practice. Pat has previously worked in the private industry for 16 years, including several years as a VP of tax and director of tax policy. After Pat chooses his most and least favorite CBTT podcasts, Doug and Pat discuss green energy credits, the Pillar Two Model Rules and administrative guidance, how the US and UK R&D credits compare under Pillar Two, refundable credits, transferable credits, the equity investment inclusion election, and qualifying flow-through tax benefits.

Doug McHoney (PwC's US International Tax Services Global Leader) is joined by Shin Yamaguchi at PwC’s 2023 International Tax Conference. Shin is a Tokyo-based International Tax Partner, where he leads PwC Japan’s Inbound Tax Practice. Doug and Shin discuss Japan’s latest tax developments, focusing on the Pillar Two rules (of course!), specifically, UTPR, IIR, Safe Harbours, QDMTT, the GloBE Information Return and effective dates. They also discuss the Japanese legislative process.Since the recording of this podcast Japan has enacted their 2023 Tax Reform Bill which includes the Pillar Two Income Inclusion Rule which applies on or after April 1, 2024.

Doug McHoney (PwC's US International Tax Services Global Leader) is joined by Craig Stonberg at PwC’s 2023 International Tax Conference. Craig is PwC’s Macro Intelligence Leader, and spearheads a team of analysts helping global businesses with geopolitical risks, macroeconomic volatility, and supply chain shifts. Doug and Craig discuss the geopolitical landscape, particularly in Asia and Europe; how a recession would affect multinational companies, the labor shortage that is particularly affecting women, the geopolitical part of the energy equation, and how multinational companies should be preparing for 2023 and beyond.

Doug McHoney (PwC's US International Tax Services Global Leader) is back in Westminster Studios with Kate Miller, a Director in PwC’s Tax Reporting and Strategy Practice. Doug and Kate discuss what is meant by Pillar Two operational readiness and PwC’s Data Input Catalog, including the data requirements, the necessity of resources, the Data Input Catalog, safe harbours, ERP and enterprise systems, the importance of working as a team, how software tools can help, and the power of a centralized rules engine. PwC’s Data Input Catalog

Doug McHoney (PwC's US International Tax Services Global Leader) records from PwC’s 2023 International Tax Conference, where he is joined by Phil Ramstetter, PwC International Tax Partner based in Chicago. Phil was formerly a tax policy consultant for Business at OECD (BIAC). Doug and Phil overcome conference background noise to discuss the recent administrative guidance, but start with a history lesson on Pillar Two, when it was merely the Digital Project. Topics covered include blended CFC regimes, GILTI, expense apportionment, loss-making jurisdictions, transition period transactions, common control, the outlook for future guidance and some of the remaining open questions.

Doug McHoney (PwC's US International Tax Services Global Leader) records from PwC’s 2023 International Tax Conference, where he is joined by Pascal Saint-Amans, former Director of the OECD's Centre for Tax Policy and Administration and current partner with Brunswick, a strategic advisory firm. Doug and Pascal dive directly into the BEPS Project with an overview of the Pillar Two origin story, the challenges and successes of the project, harmful tax practices and the ways the OECD is trying to change tax systems, the natural complexity of tax, the future of tax incentives, compliance requirements, the private sector’s role in the policy process and much more.

Doug McHoney (PwC's US International Tax Services Global Leader) is joined by Jason Black, a PwC WNTS partner in the Federal Tax Services Group. Doug and Jason start with words of wisdom for accounting majors before diving into a discussion of the Corporate Alternative Minimum Tax (CAMT), formerly known as the Inflation Reduction Act’s Book Minimum Tax. They cover the details of Notice 2023-7, including the safe harbor rules, depreciation adjustments, M&A considerations, comparisons to Pillar Two, and much more.

Doug McHoney (PwC's US International Tax Services Global Leader) is joined by Mike Olecki, PwC’s International Tax Services Global Technology Leader and partner in the Quantitative Services Tax Practice. Doug and Mike discuss the OECD Pillar Two documents released in December 2022, including the transitional CbyCR safe harbour, the potential for a permanent safe harbour, the GloBE Information Return, calculation challenges, and how technology can help.

Doug McHoney (PwC's US International Tax Services Global Leader) is joined by Pat Brown, International Tax Partner and co-Leader of the Washington National Tax Practice to look back at the very eventful and tortured 2022 year in international taxation. They cover topics including US Congressional activities, Treasury’s 2022 regulations and guidance, recent international tax and transfer pricing rulings, and the progress made on Pillar One & Two.

Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Ninee Dewar, PwC International Tax Services Principal, to discuss the recently released 2022 proposed foreign tax credit (FTC) regulations. These regulations relax some of the stringent creditability requirements that were set forth in the 2021 final FTC regulations. Doug and Ninee dive into changes to the cost recovery requirement, the attribution requirement for withholding tax on royalty payments, and the definition of a reattribution asset for purposes of allocating and apportioning foreign taxes.

Doug McHoney, PwC’s International Tax Services Global Leader, is joined by Mario Alberto Gutierez, International Tax Partner based in Mexico City, and Leader of PwC’s International Tax Practice in Mexico. Doug and Mario discuss Mexico’s implementation of the multilateral instrument, Mexican tax treaties and the potential for treaty abuse, how the 2022 Tax Act changes the game with regard to share transfers, the Maquiladora regime, the Mexican manufacturing industry more broadly including business transformations and ‘near shoring,’ and debt structures and the ‘inflation adjustment’ in Mexico. Not surprisingly, Pillar Two makes a cameo appearance.

Doug McHoney, PwC’s International Tax Services Global Leader, is in Barcelona, Spain at PwC’s Global Tax Symposium. On this episode, Doug is joined by Matt Ryan, a UK-based International Tax Partner with PwC. Doug and Matt discuss the UK’s parliamentary process, Liz Truss’s resignation, the corporate tax proposed changes, and Pillar Two, including a qualified domestic minimum tax, the income inclusion rule, and the under taxed payments rule. They also cover the finer points of UK’s treatment of asset transfers, deferred taxes, year-end adjustments, and the system and data requirements that companies must address.

Doug McHoney, PwC’s International Tax Services Global Leader, is at PwC’s Global Transfer Pricing Conference in Berlin, Germany, joined by Omri Yaniv, Global Head of Tax at Amdocs Ltd, based in Tel Aviv. Omri is a former PwC partner, and the first Tax VP from a non-US-parented company to appear on the podcast. Doug and Omri discuss the three pillars of Omri’s job, Amdocs’ tax department, the accounting talent war, recent global tax changes, and the potential changes on the horizon.

Doug McHoney, PwC’s International Tax Services Global Leader, welcomes Horacio Pena, Tax Principal, Senior Economist and PwC’s Global Transfer Pricing Network Leader, to the podcast. Doug and Horacio provide the macroview of the transfer pricing environment, covering global inflation, China’s COVID restrictions, environmental volatility, the dollar’s strengthening against other currencies, regionalization, a brief touch on Pillar Two, country-by-country reporting, and more.

Doug McHoney, PwC’s Global International Tax Services Leader, is at PwC’s Global Transfer Pricing Conference in Berlin, Germany. Doug honors Ocktoberfest by donning lederhosenis to host Arne Schnitger, PwC International Tax Partner based in Berlin. Arne hosts the German tax podcast Frisch Serviert - der Steuerpodcast. They discuss Pillar Two issues in the EU, the US, and Germany, the differences approaches each jurisdiction takes when calculating the tax, the US book minimum tax, GILTI, refundable credits, allocation of expenses, the German implementation process, tax return filing, operational readiness, German anti-hybrid rules, and German Section 49.

Doug McHoney (PwC's Global International Tax Services Leader) welcomes Rebecca Lee (Washington National Tax Services International Tax Partner). Doug and Rebecca discuss the many tax aspects of a strong US dollar, including cream skimming, foreign exchange gains and losses with branches and CFCs, previously taxed earnings, translational versus transactional gain or loss, and more. Can Doug and Rebecca go the entire podcast without mentioning a code section? Tune in to find out!

Doug McHoney (PwC's Global International Tax Services Leader) welcomes first-time guest Kristina Novak (Washington National Tax Services Transfer Pricing Principal) and returning guest Alex Voloshko (PwC’s Value Chain Transformation Leader) to discuss the Medtronic case. They highlight the key takeaways including intellectual property considerations, transfer pricing trends, licensing models, business transformation trends for customers, and of course, a brief discussion of how Pillar Two will fit in.