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Cross-border Tax Talks
39 minutes | 7 days ago
SPACs: the confluence of A-list celebs and Sec. 7874
Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Thomas Groenen (PwC's US ITS-Financial Services Leader) discuss the renewed interest in special purpose acquisition companies (SPACs). Doug and Thomas cover: how Thomas made his way from the UK to the US; Thomas's advice for individuals interested in moving to the United States to become tax professionals; what a SPAC is and how it generally functions; the history of SPACs—dating back to the British 'South Sea bubble' in the early 18th century; how SPACs compare to and interrelate with IPOs; how and why individuals and entities invest in SPACs; the tax implications for SPAC investors; considerations regarding the SPAC's jurisdiction; the SPAC lifecycle, from founding to de-SPACing; the importance of choosing the correct investment vehicle (both corporate v. pass-through and domestic v. foreign); how the passive foreign investment company (PFIC) regime interplays with foreign SPACs; and the possible future of SPACs.
40 minutes | 19 days ago
From Audit to Tax: a conversation with PwC’s US Tax Leader
Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Kathryn Kaminsky (PwC's Vice Chair - US Tax Leader) discuss Kathryn's background and her transition to PwC's US Tax Leader. Doug and Kathryn cover: Kathryn's experience as a woman in the audit and tax professions; how men can be advocates and allies for women; the differences between advocacy and mentorship; how to ensure career paths are not inhibited by the desire to have a family; Kathryn's experience as an auditor and leading practices for tax practitioners, auditors, and businesses; the challenges in communicating nuanced technical issues; challenges in transitioning from Audit to Tax and what we can learn from Kathryn's experiences over the past nine months as US Tax Leader; best practices for remote working; conversations Kathryn has been having with companies regarding potential upcoming domestic and global tax policy changes; how tax professionals can elevate issues to the C-suite; and why every business decision has a tax implication.
37 minutes | a month ago
Social justice: how the CEO Action for Racial Equity is effectuating change
Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Roy Weathers (PwC's Vice Chair for Societal Engagement and Policy Solutions) discuss Roy's new role as CEO of CEO Action for Racial Equity. Doug and Roy cover: what CEO Action for Racial Equity is and its goals; the resources businesses like PwC and other companies have committed; how CEO Action for Racial Equity is effectuating policy change to advance racial equity; how data and technology help CEO Action for Racial Equity fellows ideate policies and ideas; how the fellows analyze and prioritize issues; specific issues that CEO Action for Racial Equity is targeting, such as telehealth; potential politicization over these types of issues and how data and common interests can help overcome the politicization; Roy's experience as a Black tax professional; and how everyone can keep the momentum going to implement, cause, and create change.
38 minutes | 2 months ago
Trading places: Trade considerations for tax professionals
Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Chris Desmond (PwC's Global Trade Services Practice Leader) discuss the global trade landscape. In addition to their prognostications for Major League Baseball's NL Central division, Doug and Chris cover: how trade and tax are interrelated; how businesses can structure their trade and tax groups to encourage coordination; the 'big picture' trade landscape both inside and outside of the US; recent changes to US trade regulations; Section 301 and how Section 301 tariffs operate; impacts that Katherine Tai—President Biden's nominee for United States Trade Representative—may have on US trade policy; what duty drawback is and how businesses can utilize it; global updates to digital service taxes (DSTs) and how Section 301 tariffs interrelate with DSTs; how practical it is for businesses to shift supply chains in light of tariffs; President Biden's 'Made in America' executive order and how it may impact multinational enterprises; the importance of modeling from both a trade and tax perspective; and final pieces of advice for taxpayers.
37 minutes | 2 months ago
Grab your passport: global tax policy update
Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Will Morris (PwC's Deputy Global Tax Policy Leader) discuss important updates to international tax policy. Doug and Will cover: recent updates to the OECD's base erosion and profit shifting (BEPS) project—BEPS 2.0—including the proposed timeline for agreement, unresolved issues in the Pillar One and Pillar Two Blueprints, and potential challenges to implementation; recent IRS and Treasury appointees and how these individuals may affect domestic and international policy; the challenges of amending US treaties even if the OECD's Inclusive Framework reaches consensus; the EU Court of Justice's recent decision in Lexel AB v. Skatteverket regarding the EU's 'freedom of establishment' concept and how this decision may cause challenges in implementing Pillar Two in the European Union; recent developments concerning digital service taxes (DST), including a look at the UK's proposed online sales tax and diverted profits tax, India's equalization levy, and Indonesia's electronic transactions tax; a recent court decision in France related to a permanent establishments; and how taxpayers can prepare for international tax disruption.
43 minutes | 2 months ago
More items of interest: The final 163(j) regulations
Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Rebecca Lee (ITS Partner in PwC's Washington National Tax Services office) have much to cover with the recently released final regulations under Section 163(j). Doug and Rebecca discuss: the background of the interest expense limitation rules under Section 163(j); the content and formulation of the 2018 proposed regulations, 2020 proposed regulations, and 2020 final regulations issued under Section 163(j); the new administration's potential influence on the 2021 final regulations; how the 2021 final regulations amend the definition of 'interest' and the calculation of adjusted taxable income (ATI); how the 2021 final regulations affect C corporations, consolidated groups, and partnerships; what the CFC group election is and how companies can make the election; the many anti-abuse rules contained in the 2021 final regulations; changes to the safe-harbor election; and advice for taxpayers on how to consistently and accurately apply the multitude of rules under Section 163(j).
38 minutes | 3 months ago
Bring SALT to the table: Key state and local topics
Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Rob Ozmun (State and Local Tax (SALT) Partner in PwC's Washington National Tax Services office) peel the onion on how state and local tax issues can impact cross-border planning, and vice versa. Doug and Rob set the table with a brief primer on state and local corporate tax, then devour topics including: state conformity to the Internal Revenue Code; how different states have handled federal developments regarding subpart F income, global intangible low-taxed income (GILTI), the Section 965 'toll charge,' and the Section 250 deduction; how businesses are analyzing the dividends received deduction (DRD) under Section 245A and the GILTI high-tax exception at the state level; important state and local considerations related to the business interest expense deduction rules under Section 163(j); how states have reacted to the CARES Act; how states have implemented (or declined to implement) the base-erosion and anti-abuse tax (BEAT); and key considerations for taxpayers. Come hungry for knowledge, leave satiated.
43 minutes | 3 months ago
US tax reform 2.0? Biden's international tax campaign proposals
Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Nita Asher (ITS Partner in PwC's Washington National Tax Services office) cover some of President Biden's campaign tax proposals. Doug and Nita discuss: the current state of Congress and the White House; President Biden's campaign proposals to increase the corporate and global intangible low-taxed income (GILTI) tax rates, move the GILTI determination to a country-by-country basis, eliminate the exemption for qualified business asset investment (QBAI), amend the base erosion and anti-abuse (BEAT) tax, and implement a minimum tax on global book income; how President Biden's proposals interact with the OECD's ongoing base erosion and profit shifting (BEPS) project; the budget reconciliation process in the Senate and the likelihood of Congress enacting President Biden's proposals; what the regulatory landscape may look like under the Biden administration; and why taxpayers should engage with policymakers in a timely manner.
38 minutes | 3 months ago
Supply and demand: key value chain considerations in 2021
Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Alex Voloshko (PwC's Value Chain Transformation Leader and ITS Partner in PwC's Washington National Tax Services office) discuss key considerations for value chains in 2021. Doug and Alex define 'value chain,' and how it includes the 'supply chain,' the 'demand chain,' and more; how value chains impact tax and transfer pricing; how supply chains were disrupted in 2020 and the outlook for supply chains in the new year; the plethora of factors that go into value and supply chain planning, including cost structure, access to qualified labor and production capabilities, regulatory considerations, and tax costs; the growing pressure on companies to 'near shore' and diversify their value chains; important trends for multinational entities, including increased scrutiny from tax authorities and increased transparency; the increasing importance of managing growth in a strategic manner; and recent trends concerning permanent establishments (PE).
52 minutes | 4 months ago
WHT do you mean? A 95 year old German withholding tax on royalties
Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Dr. Arne Schnitger (Head of PwC Germany's National Tax Office) discuss withholding taxation in Germany pursuant to Section 49 of Germany's tax code. Doug and Arne discuss: the background of Germany's Section 49 withholding tax and the circumstances under which Section 49 applies; the recent Circular issued by the German authorities discussing the application of Section 49; potential legal challenges to Section 49 taxation, including constitutionality and estoppel; the definition of 'German-registered IP' and 'EU-registered IP', and how tax advisers determine which royalties are subject to tax under Section 49; the interplay between withholding taxation and treaty jurisdictions; the importance of exemption certificates for prospective payments; what companies should do regarding historic liabilities; potential penalties for failure to file and/or remit tax as required by Section 49; and final pieces of advice for multinational taxpayers impacted by Section 49. [NOTE: The majority of this episode was recorded prior to the German Ministry of Finance's release of draft, proposed legislation (in German) regarding the effective repeal of Section 49(1) on an extraterritorial basis as it applies to IP registered in Germany. During the final five minutes of this podcast, Doug and Arne discuss key takeaways from this draft legislation.]
38 minutes | 5 months ago
Extension cord: The story of tax extenders
Doug McHoney (PwC's US International Tax Services Leader) and Rohit Kumar (co-leader of PwC's Washington National Tax Services practice) discuss the past, present, and future of tax extenders. Doug and Rohit discuss: Rohit's experience as Domestic Policy Director and Deputy Chief of Staff for Senate Majority Leader Mitch McConnell; what tax extenders are and why they exist; the importance of the ten-year congressional budget window; the political calculus involved in determining whether certain tax provisions are temporary or permanent; the background and history of the controlled foreign corporation (CFC) look-through rule; potential alternatives to the tax extender regime; and the necessity for bipartisanship due to the upcoming 'fiscal cliff' at the end of 2025, caused by the potential expiration of a multitude of Tax Cuts and Jobs Act (TJCA) provisions.
42 minutes | 5 months ago
Going for the gold: macroeconomics in 2021 and beyond
Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Craig Stronberg (leader of Macro Capability for PwC Intelligence) discuss key macroeconomic considerations after November's elections. Doug and Craig discuss: the global implications of President-elect Biden's upcoming administration; the potential for tax reform in 2021 and beyond; the future of trade and diplomacy with China, including potential changes to supply chains, onshoring, and digital currencies; trends in 'protectionism' both inside and outside the US; key advice Craig has for executives and multinational corporations in light of the current geopolitical uncertainties; and Craig's experience working to protect the Olympic games.
50 minutes | 6 months ago
Hard hat area: the OECD's Blueprints on Pillar One and Pillar Two
Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Pat Brown (PwC's International Tax Policy Leader) discuss the OECD's recently released blueprints on Pillars One and Two. Doug and Pat discuss: Pat becoming the most frequent Cross-border Tax Talks guest (four) and the sizing for Pat's 'Five-Timers' jacket when he next appears (spoiler: 42 Long); the background of the OECD's base erosion and profit shifting (BEPS) project and the progression from 'BEPS 1.0' to 'BEPS 2.0'; the background of Pillar One, including a discussion of 'Amount A' and 'Amount B'; the background of Pillar Two, including a discussion of the 'undertaxed payments rule' and the 'income inclusion rule'; highlights from the OECD's Blueprint on Pillar One, including the concept of 'consumer-facing businesses'; highlights from the OECD's Blueprint on Pillar Two, including the OECD's 'jurisdictional-blending' approach and the 'income-inclusion' regime; and what the future looks like for BEPS 2.0 implementation in 2021 and beyond.
42 minutes | 6 months ago
You down with FTC? The new Foreign Tax Credit regulations
Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Mike Urse (ITS Partner in PwC's Washington National Tax Services practice) discuss the recently released final and proposed foreign tax credit (FTC) regulations. Doug and Mike (who participated in our inaugural CBTT podcast over two years ago) go deep on interest, stewardship, and research and development (R&D) expense apportionment under the final FTC regulations; the importance in modeling potential retroactivity of the R&D regulations; the intricacies in allocating and apportioning foreign taxes; foreign tax redeterminations under Section 905(c); the 'disregarded payment rule' under the proposed regulations; how to determine if a tax is 'creditable' and the new concept of 'jurisdictional nexus' in the proposed regulations; the revocation of the 'contested tax doctrine,' and additional proposed changes to the research and expenditure (R&E) allocation rules. Mike leaves listeners with a nice summary of the highlights and key takeaways from these regulations.
34 minutes | 6 months ago
Tales from the crypt(o) - Global taxation of digital assets
Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Mazhar Wani (PwC's FinTech Tax Leader) discuss PwC's Annual Global Crypto Tax Report and recent developments concerning digital assets. Doug and Mazhar discuss: what 'digital assets' are; the OECD's recent report, 'Taxing Virtual Currencies,' and how it compares with PwC's Annual Global Crypto Tax Report; the distinctions between cryptocurrencies and digital assets; the increase in guidance concerning digital assets and potential incentives for jurisdictions to lead in the digital asset space; how regulators around the world are treating the taxation of digital assets; the importance of classifying digital assets as 'property' or 'currency,' and distinctions between the two classifications; what 'staking' is and recent global trends regarding 'staking'; what 'decentralized finance' (DeFi) is and the future of DeFi; trends in the indirect tax space concerning digital assets; and recommendations for taxpayers looking to enter the digital asset space.
39 minutes | 7 months ago
Extraordinary Considerations: the 245A DRD regulations
Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Aaron Junge (ITS Partner in PwC's Washington National Tax Services practice) discuss the recently-released final and proposed dividends received deduction (DRD) regulations under Section 245A. Doug and Aaron discuss: Aaron's background as Tax Counsel for the Committee on Ways and Means in the US House of Representatives and how this experience proves valuable in the private sector; the background and architecture of Section 245A; important topics included in the final and proposed DRD regulations including hybrid dividends, extraordinary dispositions (ED), and extraordinary reductions (ER); topics not fully contemplated in the final and proposed regulations, including certain mechanical rules of the DRD; how the ED rules interplay with the global intangible low-taxed income (GILTI) and Section 965 'toll charge' rules; notable changes from the 2019 temporary DRD regulations to the 2020 final DRD regulations, including changes to the treatment of sales of intellectual property (IP) and mitigating the circumstances in which the DRD rules produce double-taxation; what an ER is and how the final regulations clarify the year-end close election; and major takeaways from the proposed regulations, including coordination of the ED rules and application of the disqualified basis rules.
36 minutes | 7 months ago
Road to Election 2020 with Chairman Dave Camp
Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Chairman Dave Camp (Senior Policy Advisor in PwC's Washington National Tax Services practice and former Chairman of the House Committee on Ways and Means) discuss the past, present, and future of tax policy. Doug and Chairman Camp discuss: Chairman Camp's proposals for a global minimum tax during his tenure in Congress and how his proposals compare to the OECD's Base Erosion and Profit Shifting (BEPS) project; Vice President Biden's tax proposals, including amending the corporate tax rate, imposing a tax on book income, eliminating tax preferences for certain industries, and doubling the tax rate for global intangible low-taxed income (GILTI); the roles that the Senate, the US economy, and the global economy play in potential tax reform; President Trump's tax proposals; the evolution of the 'party platform,' political parties, and political factions; similarities and differences between the American political system and parliamentary systems; and the impact and utility of social media in the political sphere. [NOTE: This episode was recorded prior to the release of the "The Biden-Harris Plan to Fight for Workers" fact sheet released on September 9 by the Biden-Harris campaign.]
35 minutes | 7 months ago
GILTI as charged (3rd booking): the 2020 high-tax exception regs
Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Elizabeth Nelson (ITS Partner in PwC's Washington National Tax Services) discuss the recently-issued final and proposed high-tax exception regulations under the global intangible low-taxed income (GILTI) and subpart F income regimes. Doug and Elizabeth unpack: the background and history of the high-tax exception; the similarities and differences between the previously proposed high-tax exception regulations and the final high-tax exception regulations; how the regulations interact with net operating losses (NOLs) and the base erosion and anti-abuse tax (BEAT); what happened to QBUs, what is a 'tested unit,' and how the aggregation rules apply to tested units; the substance and implications of the 'consistency rule,' how the proposed regulations treat expense apportionment and negative interest rates; the new documentation requirements and anti-abuse rules contained in the regulations; and the continued importance of modeling due to the high-tax exception's interaction with many other TCJA provisions. Doug and Elizabeth also 'put a fork' in the notion that GILTI is a minimum tax and identify three categories of multinational taxpayers that may want to elect the high-tax exception.
35 minutes | 8 months ago
Items of interest: The 163(j) Regulations
Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Rebecca Lee (ITS Partner in Washington National Tax Services) discuss the recently-issued Section 163(j) final and proposed regulations. Doug and Rebecca discuss: what Section 163(j) is and how the Tax Cuts and Jobs Act changed the interest expense limitation rules for corporations; effective dates for both the final and proposed regulations; how the final regulations define 'interest;' the breadth of the anti-avoidance rule in the final regulations; how the final regulations define 'adjusted taxable income' and 'tentative taxable income;' how the final regulations treat the separate return limitation year (SRLY) limitation; and major takeaways of the proposed regulations, including how the proposed regulations treat controlled foreign corporations (CFCs), foreign persons with effectively-connected income (ECI), and partnerships.
39 minutes | 8 months ago
Second bite of the Apple: the EU State Aid decision
Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Calum Dewar (a Partner in PwC's Washington National Tax Services (WNTS) ITS practice and leader of PwC's US Integrated Global Structuring practice) discuss the recently-issued Apple State Aid opinion from the General Court of the European Union. Doug and Calum discuss: what State Aid is; what the General Court's opinion says and how to interpret it; the procedure behind the European Commission's initial 2016 decision, including why Apple was not actually the defendant in the initial case, but why both the Irish government and Apple appealed the EC's decision to the General Court; the impact of US cost-sharing rules and transfer pricing methodologies on the General Court's decision; the role of 'selectivity' in State Aid; how the EC may act in this case, and in other State Aid cases, going forward; and what impact digital services taxes and the OECD's base erosion and profit shifting (BEPS) project may have on State Aid in the future.
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