Cross-border tax talks

Cross-border tax talks

www.pwc.com/us/en/services/tax/multinationals/podcasts.html
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?


FDII shades clearer: the final Section 250 regulations
Jul 30 • 35 min
Doug McHoney (PwC’s US International Tax Services (ITS) Leader) and Ninee Dewar (a Partner in PwC’s Washington National Tax Services (WNTS) ITS practice) discuss the recently-released Foreign Derived Intangible Income (FDII) final regulations under…
The evolution of ‘cut and paste’: 40 years of tax policy
Jul 17 • 41 min
Doug McHoney (PwC’s US International Tax Services (ITS) Leader) and Pam Olson (PwC’s US Deputy Tax Leader and Washington National Tax Services (WNTS) Practice Leader) discuss Pam’s storied career as she retires from PwC. Doug and Pam talk: life as a tax…
A conversation about race in the tax profession
Jun 25 • 39 min
Doug McHoney (PwC’s US International Tax Services (ITS) Leader) and Stephen Mosha (an ITS Partner and leader of PwC’s Northeast Tax practice) have a candid conversation about Stephen’s life as a Black tax professional. Doug and Stephen discuss:…
DAC6 Update: the latest EU disclosure rules
Jun 12 • 42 min
Doug McHoney (PwC’s US International Tax Services (ITS) Leader) and Maarten Maaskant (an ITS Partner and ITS Desk Leader) discuss the EU’s mandatory reporting rules (EU Council Directive 2018/822, also known as ‘DAC6.’) Doug and Maarten cover: the…
Whirlpool Decision: the Tax Court analyzes ‘branch rules’
May 26 • 44 min
Doug McHoney (PwC’s US International Tax Services Leader) and Tom Quinn (a Partner in PwC’s International Tax Services practice specializing in Value Chain Transformation) analyze the US Tax Court’s recently issued decision in Whirlpool v. Commissioner.…
US Tax Reform Update: The final anti-hybrid regulations
May 1 • 34 min
Doug McHoney (PwC’s US International Tax Services Leader) and Neil Edwards (a Partner in PwC’s ITS practice) analyze recently released guidance on the ‘anti-hybrid rules’ under Section 267A. Doug and Neil discuss: the general overview of the regulation…
The CARES Act: a primer for cross-border tax professionals
Apr 10 • 37 min
Doug McHoney (PwC’s US International Tax Services Leader) and Mike DiFronzo (PwC’s Washington National Tax Services ITS Leader) do a deep dive into the recently enacted CARES Act. Doug and Mike discuss: the general structure of the tax provisions included…
Global Tax Update: Around the world in 35 minutes
Mar 13 • 37 min
Doug McHoney (PwC’s US International Tax Services Leader) and Pat Brown (PwC’s International Tax Policy Leader) discuss the past, present, and future of US and global corporate taxation in 2020 and beyond. Doug and Pat discuss: issued and pending TCJA…
Merging lanes: key MA and international tax considerations after TCJA
Feb 21 • 36 min
Doug McHoney (PwC’s US International Tax Services Leader) and Mark Boyer (a Partner in PwC’s Washington National Tax MA practice) discuss key MA and international tax considerations after the Tax Cuts and Jobs Act (TJCA). Doug and Mark discuss: life at…
Sourcing sorcery: New inbound taxation regs
Feb 14 • 35 min
Doug McHoney (PwC’s US International Tax Services Leader) and Nils Cousin (International Tax Director in PwC’s Washington National Tax Services practice) discuss the intricacies of income sourcing and the recently proposed Section 863(b) and 865…
Brexit stage left: See EU later
Jan 31 • 33 min
Doug McHoney (PwC’s US International Tax Services Leader) and Matt Ryan (Leader of PwC UK’s International Tax and Treasury Network) avoid the temptation of debating Megxit and dive quickly instead into Brexit. More specifically they cover: the importance…
The New FTC Regs: Calculating tax in a galaxy far, far away
Jan 20 • 42 min
Doug McHoney (PwC’s US International Tax Services Leader) and Tim Anson (International Tax Partner in PwC’s Washington National Tax Services practice) discuss the recently issued final and proposed foreign tax credit (FTC) regulations. Doug and Tim…
Tech Talk: How Leaders in Tax Embrace Technology
Jan 3 • 29 min
Doug McHoney (PwC’s US International Tax Services Leader) and Roy Weathers (PwC’s Vice Chair and US Tax Leader) ‘co-develop’ a podcast and discuss the dynamic nature of US and global tax reform, and how the tax practitioner’s role continues to evolve…
We got the BEAT: US Tax Reform Regulations
Dec 20, 2019 • 37 min
Doug McHoney (PwC’s US International Tax Services Leader) and Nita Asher (an International Tax Partner in PwC’s Washington National Tax Services practice) discuss the background to, and recent guidance for the Base Erosion and Anti-abuse Tax (BEAT). Doug…
BEPS 2.0: It’s easy as (Amounts) A, B, C
Dec 6, 2019 • 43 min
Doug McHoney (PwC’s US International Tax Services Leader) and Will Morris (PwC’s Deputy Global Tax Policy Leader) pass an interesting smell test on the way to discussing the ‘Digitalization of the Economy Project,’ which Will reluctantly allows us to…
Reforma en México: A tax reform discussion
Nov 25, 2019 • 36 min
Doug McHoney (PwC’s US International Tax Services Leader) and Lissett Tautfest (PwC’s International Tax Services Leader in Mexico) discuss a multitude of topics related to Mexican tax reform. Specific points of conversation include: the legislative…
Properly attributing: a conversation on tax attribution after the TCJA
Nov 8, 2019 • 32 min
Doug McHoney (PwC’s US International Tax Services Leader) and Aaron Junge (Tax Director in PwC’s Washington National Tax Services office) go deep into attribution and determining ownership, focusing on Section 958(b)(4). Doug and Aaron discuss…
The Trade War: A Discussion on Trade and Tariffs
Oct 25, 2019 • 37 min
Doug McHoney (PwC’s US International Tax Services Leader) and Chris Desmond (PwC’s Global Trade Services Leader) take the podcast from below the line to above, discussing a topic generating global headlines and concern: trade. What is ‘trade’ and why it…
Clarity in the cloud: analyzing the new digital content and cloud computing regulations
Oct 11, 2019 • 35 min
Doug McHoney (PwC’s US International Tax Services Leader) and Matt Chen (a Partner in PwC’s Washington National Tax Services ITS Practice) discuss recently proposed digital content and cloud computing regulations. Doug and Matt cover a wide range of…
No havering here: BEPS 2.0 goes beyond digital
Sep 27, 2019 • 41 min
Doug McHoney (PwC’s US International Tax Services Leader) finally convinces Calum Dewar (PwC’s US Integrated Global Structuring Leader) to join him in the DC studio. They discuss what is commonly referred to as ‘BEPS 2.0’, but not before covering…
Mic flip: Doug McHoney talks candidly about tax reform
Sep 16, 2019 • 29 min
The interviewer becomes the interviewee in this episode as Sindhu Blume (Host and Executive Producer of PwC’s Policy on Demand web series) interviews Doug McHoney (PwC’s US International Tax Services Leader) about his strategy for tax planning in a…
Technically, you’re not wrong, but we need a few TCJA corrections
Aug 30, 2019 • 35 min
Doug McHoney (PwC’s US International Tax Services Leader) and Pam Olson (PwC’s US Deputy Tax Leader and Washington National Tax Services Leader) discuss technical corrections as a way to ‘fix’ scrivener’s errors, missed cross-references and drafting…
Taxing Cryptocurrency: When a currency is not a currency
Aug 20, 2019 • 37 min
Doug McHoney (PwC’s US International Tax Services Leader) and Rebecca Lee (a PwC ITS Partner specializing in cross-border financial transactions) discuss cryptocurrency, from its basic definition to its impact on taxpayers. Doug and Rebecca address…
Invalidity: When and why are tax regulations invalid?
Aug 5, 2019 • 38 min
Doug McHoney (PwC’s US International Tax Leader) and Pat Brown (PwC’s US International Tax Policy Leader) discuss the validity of tax regulations. Doug and Pat discuss why a regulation might be considered invalid, and what taxpayers should consider when…
The DRD 245A regs: Did the donut hole eat the donut?
Jul 23, 2019 • 36 min
Doug McHoney (PwC’s International Tax Services Leader) interviews Tim Anson (ITS Partner) about the recent temporary regulations under Section 245A. They provide background on the new law, and discuss its application and potential impact on taxpayers.…
Branch FX: Were those Section 987 regulations final?
Jul 9, 2019 • 35 min
Doug McHoney (PwC’s International Tax Services Leader) and Laura Valestin (International Tax Services Partner) discuss Section 987, from one sentence in the Internal Revenue Code to many iterations of regulations. Doug and Laura cover the basic mechanics…
GILTI as charged - Part 2: The Final Regs and High Tax Exception
Jun 25, 2019 • 37 min
Doug McHoney (PwC’s International Tax Services Leader) interviews Elizabeth Nelson (International Tax Services Partner) and Aaron Junge (International Tax Services Director) about the final and newly proposed GILTI regulations. Elizabeth and Aaron walk…
Tax Reform with a slice of Swiss
Jun 10, 2019 • 34 min
Doug McHoney (PwC’s International Tax Services Leader) and Pascal Buehler (ITS partner on secondment from PwC Switzerland) cover various aspects of Switzerland’s recent popular vote on tax reform. Doug and Pascal discuss the major changes to the Swiss tax…
Mushy Peas: Comparing the UK and US’s Corporate Tax Reforms
May 24, 2019 • 36 min
The UK and the US recently have undertaken corporate tax reform and now are experiencing its impacts. Doug McHoney (PwC’s International Tax Services Leader) and Neil Edwards (ITS partner on secondment from PwC London) compare and contrast aspects of tax…
A Fortune 50 Tax VP’s perspective on tax reform
May 13, 2019 • 33 min
Doug McHoney (PwC’s US International Tax Services Leader) interviews Tadd Fowler (VP of Tax Operations and Assistant Treasurer at The Procter and Gamble Company) who is the first taxpayer to join the podcast series! Doug and Tadd reflect on TCJA, the…
A practitioner’s brief history of international tax in the US
Apr 29, 2019 • 35 min
Doug McHoney (PwC’s US International Tax Services Leader) interviews Richard McGinnis (Retired PwC International Tax Partner) about his experiences and the evolution of international tax as an issue and a profession. Doug and Richard discuss depreciation…
US Tax Reform: An Insider’s Perspective for CFOs
Apr 15, 2019 • 34 min
Doug McHoney (PwC’s US International Tax Services Leader) interviews John Harrell (PwC US International Tax Partner) about how CFOs and tax departments are reacting to the significant changes from tax reform. Doug and John cover John’s transition from…
FDII shades of gray
Apr 1, 2019 • 37 min
Doug McHoney (PwC’s US International Tax Services Leader) interviews Alex Voloshko (PwC’s US Value Chain Transformation Leader) and Marco Fiaccadori (PwC Transfer Pricing Principal) about the recently released Foreign Derived Intangible Income (FDII)…
Engineering the post-tax reform world: a policy perspective
Mar 18, 2019 • 38 min
Doug McHoney (PwC’s US International Tax Services Leader) interviews Pat Brown (PwC US International Tax Policy Leader) about the policy ideas behind tax reform. Among other topics, they discuss Pat’s career in both the public and private sector, the…
Around the geopolitical (and tax) world in 30 minutes
Mar 11, 2019 • 30 min
Doug McHoney (PwC’s US International Tax Services Leader) and Alexis Crow (PwC Geopolitical Investing Director) discuss the interaction of the geopolitical environment and the evolving tax landscape. Among other topics, they cover the latest developments…
Behind the Curtain: The Joint Committee on Taxation
Mar 4, 2019 • 41 min
Doug McHoney (PwC’s US International Tax Services Leader), Kevin Livingston (PwC International Tax Services Partner), and Karl Russo (PwC’s National Economics and Statistics Director) discuss the inner workings of the Joint Committee on Taxation (JCT).…
Final Section 965 regulations: Amended tax returns ahead?
Feb 18, 2019 • 38 min
Doug McHoney (PwC’s US ITS Leader) interviews Prae Kriengwatana (WNTS- ITS Director) about the Section 965 Final Regulations which were published in the Federal Register on February 5, 2019. Doug and Prae discuss the background of Section 965, review the…
Temas candentes: Hot issues in Mexican tax
Feb 4, 2019 • 34 min
Doug McHoney (PwC’s US International Tax Services Leader) and Lissett Tautfest (PwC ITS Partner) dive into cross-border elements of the Mexican tax system. Among other topics, they cover Mexican investment into the US, non-resident capital gains, foreign…
Anti-hybrid rules: the forgotten reform provisions
Jan 18, 2019 • 35 min
Doug McHoney (PwC’s US International Tax Services Leader) and Nils Cousin (PwC ITS Director) discuss recently released regulations under Sections 245A and 267A. Among other topics, they cover for 245A, the notional interest deductions, eligibility for the…
Section 163(j) - A brave new world for partnerships
Dec 18, 2018 • 36 min
Doug McHoney (PwC’s US International Tax Services Leader) and Craig Gerson (PwC MA Partner) explore, with a partnership lens, the significant changes and surprises provided by new Section 163(j), the US interest deduction limitation. Among other 163(j)…
Your foreign tax credits after tax reform - a basket case?
Dec 18, 2018 • 32 min
Doug McHoney (PwC’s US International Tax Services Leader) and Elizabeth Nelson (PwC International Tax Services Partner) discuss the amended Foreign Tax Credit regime and the recently released proposed regulations. Among other topics, they cover expense…
The global tax environment from an OECD perspective
Nov 26, 2018 • 35 min
Doug McHoney (PwC’s US International Tax Services Leader) interviews Philip Ramstetter (PwC International Tax Services Director) about his secondment at Business at OECD (BIAC). Doug and Phil discuss the OECD’s approach to multi-lateral rule making in…
Trading places: the intersection of tax and trade
Nov 26, 2018 • 33 min
Doug McHoney (PwC’s US International Tax Services Leader) tackles the ever changing trade climate by interviewing Jonathan Lieber (a PwC National Economics and Statistics Principal). Doug and John discuss the administration’s approach to global trade…
Widgets on hold: Shedding light on sovereign wealth and pension funds
Nov 9, 2018 • 33 min
Doug McHoney (PwC’s US International Tax Services Leader) helps shed light on the global financial services sector by interviewing Oscar Teunissen (a PwC International Tax Financial Services Partner). Doug and Oscar discuss the market trends, policy, and…
Triangles add complexity to our square world
Oct 29, 2018 • 31 min
Doug McHoney (PwC’s US International Tax Services Leader) dives into the complicated world of partnerships. In this episode, Doug and Karen Lohnes (PwC M and A Partner) discuss unwinding partnerships, basis adjustments, and subchapter K in the context of…
US Tax Reform: GILTI as charged!
Oct 10, 2018 • 33 min
Doug McHoney (PwC’s US International Tax Services Leader) focuses again on US Tax Reform. In this episode, Doug and Matt Chen (PwC ITS Partner) dive into the Global Intangible Low-taxed Income (GILTI) provision and the recently released proposed…
European Union State aid: a $13 Billion (and counting) issue!
Sep 25, 2018 • 34 min
Doug McHoney (PwC’s US International Tax Services Leader) focuses again on the European Union. In this episode, Doug and Wybe Mebius (Netherlands International Tax Partner) discuss the EU’s efforts to address State aid. They define State aid and its…
Update on global tax reform: ATAD, MLI, DAC6
Sep 10, 2018 • 36 min
Doug McHoney - PwC’s US International Tax Services Leader - interviews Maarten Maaskant - US International Tax Desk Leader - about three major tax reforms: the EU’s Anti-Tax Avoidance Directives ATAD; the OECD’s BEPS Action Item 15, or Multilateral…
US Tax Reform: Understanding Treasury’s Role
Aug 29, 2018 • 34 min
Doug McHoney - PwC’s US ITS Leader - interviews Pam Olson - PwC’s US Deputy Tax Leader and WNTS Practice Leader - about her previous role at US Treasury. Pam discusses the interaction between Congress and the Treasury, including how US Tax Reform came to…
Key findings: Sec 965 Proposed Regs
Aug 21, 2018 • 37 min
Doug McHoney (PwC’s US ITS Leader) interviews Prae Kriengwatana (WNTS International Tax Services Director) about the Section 965 Proposed Regulations which were released August 1, 2018. Doug and Prae discuss the significant aspects of the regulations and…
Cross-border tax talks: Tax regulations: behind the scenes
Aug 1, 2018 • 30 min
Doug McHoney (PwC’s International Tax Services Leader) interviews Mike DiFronzo (WNTS-International Tax Services Leader) about his role as ‘Deptech’ at the IRS. Mike shares his experience regarding how new regulations are issued, including prioritizing,…
Cross-border tax talks: Treasury considerations after tax reform
Jul 20, 2018 • 34 min
Doug McHoney (PwC’s International Tax Services Leader) discusses the uncertainty around how US tax reform will affect treasury issues such as external debt, cash pooling, and intercompany loans with Rebecca Lee (ITS-Washington National Tax partner) who…
Cross-border tax talks: International tax provisions
Jun 29, 2018 • 33 min
On the heels of the six month anniversary of the Tax Cuts and Jobs Act becoming law, Doug McHoney, PwC ITS Leader, and Mike Urse, former PwC ITS Leader, provide a general overview of the various issues companies have identified with the new international…