Cross-border Tax Talks

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US CAMT Proposed Regs: You are no Pillar Two Oct 11, 2024

Show notes

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by returning guest Aaron Junge, an International Tax Partner in PwC’s Washington National Tax Services Practice. Aaron served as Tax Counsel to the US House of Representative during the passing of the Tax Cuts and Jobs Act in 2017. Doug and Aaron briefly discuss the College World Series held in Aaron’s hometown of Omaha, before delving into the Corporate Alternative Minimum Tax (CAMT) proposed regulations. Specifically, they discuss Adjusted Financial Statement Income (AFSI), how the rules affect large domestic and foreign investment funds and partnerships, the open comment period, the similarities (and differences) between CAMT and Pillar Two, whether or not CAMT could be converted to a QDMTT, how the regulations impact adjustments for depreciation, and new foreign stock rules.

Business Model Reinvention: Tax Implications Sep 25, 2024

Show notes

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by returning guest Alex Voloshko, an International Tax Partner in PwC’s Washington National Tax Services Practice where he specializes in value chain transformation and the tax implications of business operating models. Doug and Alex discuss how tax interacts with the broader business, the evolution of the tax operating model, business model reinvention, the importance of data, supply chain management, IP trends from the 2017 TCJA, and the potential impact of Pillar Two.

No double dipping! US proposes new regulations Sep 13, 2024

Show notes

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by returning guest Elizabeth Nelson, a Partner in PwC’s Washington National Tax Services Practice to discuss the recently proposed regulations that address dual consolidated loss (DCL) rules as well an entirely new tax regime regarding disregarded payment losses (DPLs). Together they dive into the background of the US DCL rules, effective dates, foreign use, intercompany transactions, stock inclusions, mirror legislation, a new anti-avoidance rule, and of course the application of the DCL rules to Pillar Two.

Taxing Cryptocurrency: US Digital Asset Regs Aug 28, 2024

Show notes

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by returning guest Rebecca Lee, a Principal in PwC’s Washington National Tax Services Practice where she focuses on complex tax problems and financial transactions in the digital asset space. Doug and Rebecca discuss T.D. 10000, the recently published final regulations dealing with digital assets. They dive into the details of digital assets, including the definition of a digital assets, revisiting non-fungible tokens (NFTs) and blockchain, and the different types of digital transactions. They also cover the background of the final regulations, calculating gains and losses, determining basis, digital asset transaction costs, ordering rules, Form 1099-DA, Notices 2024-56 & 2024-57, and the applicability dates. They finish the podcast with an exploration of how other jurisdictions are approaching cryptocurrencies around the world, touching on FATCA, DAC8 and more.

US Election Watch: Tax Implications Aug 14, 2024

Show notes

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Janice Mays (Managing Director in PwC’s Tax Policy Services) who boasts a 40 year career on the Hill including 22 years as the Democratic chief counsel and staff director for the House Ways and Means Committee, to discuss the upcoming US election’s impact on tax policy. Doug and Janice dive into the practice and procedures behind US tax policy, the upcoming US presidential election, and the key races to watch in the US Senate and House of Representatives. They also cover various election result scenarios, the key priorities for both Republicans and Democrats in a 2025 tax bill, and a potential US reaction to Pillar Two.

US Supreme Court Update: Chevron is no Moore Jul 30, 2024

Show notes

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Wade Sutton, International Tax Leader for PwC’s Washington National Tax Practice. Doug and Wade kick off with the persona of a law school professor, providing an overall perspective on the US common law system, and how the US court system works. They then cover the importance three of Supreme Court’s recent tax case decisions – Moore v. United States, Corner Post v. United States, & Loper Bright v. United States. They start by ‘briefing’ the cases before noting why taxpayers should pay attention to each case. Additionally, they cover a potential wealth tax, the possible effects of the cases on litigation and tax controversy, what constituted the majority opinion in Loper Bright, the overruling of the Chevron doctrine, and regulatory validity.

Pillar Two Admin Guidance Glimpses of clarity Jul 17, 2024

Show notes

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Phil Ramstetter, International Tax Partner and former Tax Policy Consultant at Business at OECD (BIAC). Doug and Phil discuss the OECD’s Administrative Guidance released in June 2024, including the deferred tax liability (DTL) recapture rule or five-year rule, the allocation of cross-border taxes, deferred tax accounting, transactions within the GloBE rules, entity classification and treatment, and the expectation of more OECD administrative guidance in the second half of 2024.

US Stock Buyback Tax: a funding conundrum Jun 26, 2024

Show notes

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Nita Asher, International Tax Partner in PwC’s Washington National Tax Practice and former legislative counsel to the Joint Committee of Taxation during the enactment of TCJA in 2017. Doug and Nita focus on the Stock Buyback Excise Tax enacted under the Inflation Reduction Act. Doug and Nita walk through Notice 2023-2, the recently released procedural and technical regulations, including the elimination of the per se rule, the funding rule, and which other countries are considering similar rules. They also discuss how the excise tax could present a multi-year reporting exercise for taxpayers, utilizing Forms 720 and 7208. Non-US headquartered companies will be very interested in this conversation!

Pillar Two Potpourri: Where is this heading? Jun 12, 2024

Show notes

Doug McHoney (PwC’s International Tax Services Global Leader) is with Pat Brown, Washington National Tax Services Co-Leader, to discuss the complex state of international tax today and where the winds of Pillar Two are blowing. Doug and Pat bare their ankles and kick off the discussion with the state of international tax when Pat graduated law school. They cover the increasing complexity of tax regimes, before diving into Pillar Two, the Undertaxed Payments Rule (UTPR), qualified CbC reporting, business concerns and struggles, the United Nations’ role in international tax, and recently published Belgian Pillar Two registration requirements.

Pillar Two in Ireland: It takes a village May 30, 2024

Show notes

Doug McHoney (PwC's Global International Tax Services Leader) and Peter Reilly (PwC International Tax Partner & Ireland’s Tax Policy Leader) are at PwC EMEA’s International Tax Academy in Prague to discuss Ireland’s implementation of Pillar Two. Doug and Peter dive into why Irish policy makers agreed to adopt the Pillar Two regime, how Ireland is incorporating the OECD guidance, the potential effects on the Irish economy and current tax regime, the ways Irish multinationals are preparing, and the potential ramifications in the future.

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