Doug McHoney (PwCâ��s International Tax Services Global Leader) is joined by Tadd Fowler, Senior Vice President Treasurer and Global Taxes of Procter & Gamble. With nearly two decades at P&G, Tadd shares insights from his dual leadership in tax and treasury. Doug and Tadd discuss P&Gâ��s approach to tax certainty, compliance in over 180 jurisdictio…

A review of the week's major US international tax-related news. In this edition: US House leadership offers budget reconciliation timeline – Recent Trump Executive Order on OECD global tax deal may not necessarily affect IRS guidance on BEPS Pillar One Amount B – Hungary’s PM authorizes US tax treaty negotiation.…

A review of the week's major US international tax-related news. In this edition: President Trump signs Executive Orders on BEPS project and trade policy – US House Ways & Means Committee Chairman introduces bill to punish countries imposing discriminatory taxes against US companies – President Trump addresses Davos Economic Forum on US taxation – I…

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Laura Williams, an International Tax Principal at PwC’s Washington National Tax Services office. Laura previously worked as the International Branch Chief at the IRS Office of Chief Counsel. Doug and Laura discuss the long awaited previously taxed earnings and profits (PTEP)…

A review of the week's major US international tax-related news. In this edition: President-elect Trump to usher in new administration on 20 January – US House passes Taiwan tax bill – US officials address CAMT guidance – US, France issue statement on exchange of CbC reports for 2024 and 2025 – US officials comment on BEPS 2.0 project – OECD IF co-c…

A review of the week's major US international tax-related news. In this edition: President-elect Trump open to two budget reconciliation bills, prefers one – House W&M Committee leaders introduce Taiwan tax bill – IRS issues comprehensive package on classification, sourcing of digital content and cloud transactions – IRS releases final regulations …

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Will Morris, PwC’s Global Tax Policy Leader and former Director of Global Tax Policy at General Electric to look ahead to potential global tax policy changes. Will enlightens Doug about the confluence of tax and tariffs, digital services taxes (DSTs), the importance of commu…

A review of the week's major US international tax-related news. In this edition: US House and Senate return to Washington, House retains Johnson as Speaker – Congressional Republicans lack unanimity on path forward for budget reconciliation – IRS releases technical corrections to CAMT regulations – IRS issues final consolidated return regulations –…

A review of the week's major US international tax-related news. In this edition: US Congressional Republicans continue to hold differing views on 2025 budget reconciliation – US to adopt OECD's Amount B simplified and streamlined approach to intercompany transactions beginning 2025 – US announces partial suspension of 1973 US-USSR tax treaty applic…

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Andy Wiggins, PwC Partner based in the United Kingdom and PwC’s Global Tax Accounting Services Leader to(birming)ham it up on the tax accounting implications of Pillar Two. Together they discuss, deferred accounting, the differences between US Generally Accepted Accounting P…

A review of the week's major US international tax-related news. In this edition: US Congressional Republicans consider plans for budget reconciliation bills in 2025 – Congress must pass government funding by 20 December, US-Taiwan tax bill still possible – IRS issues final and proposed FX regulations – US-Norway CAA released – IRS requests comments…

Doug McHoney (PwCâ��s International Tax Services Global Leader) is joined by returning guest Matt Ryan, a PwC International Tax Partner based in London and leader of PwC UKâ��s International Tax and Treasury Network. Doug and Matt discuss a selective list of Pillar Two issues and topics related to the UK Finance Bill 2024-25. They provide an update…

A review of the week's major US international tax-related news. In this edition: Congressional Republicans consider budget reconciliation options to enact legislative agenda – Congress to address government funding that expires on 20 December 2024 – President-elect Trump nominates new IRS Commissioner – IRS releases long-awaited PTEP proposed regul…

Doug McHoney (PwCâ��s International Tax Services Global Leader) is joined by Stewart Brant, Managing Director in PwCâ��s Tax Policy Services to discuss the latest Pillar Two developments. Doug and Stewart start off â�� after baseball of course â�� discussing the purpose of the Digital Tax Study Group. Then they cover the status of Pillar Two enactm…

A review of the week's major US international tax-related news. In this edition: President-elect Trump nominates Treasury Secretary, fills out economic team G20 Leaders’ Declaration addresses international tax and BEPS 2.0 project OECD Global Forum on Transparency / Information Exchange announces 61 jurisdictions joining CARF…

A review of the week's major US international tax-related news. In this edition: Congressional Republicans eye two budget reconciliation bills in 2025 to enact tax legislation – OECD holds Tax Certainty Day, releases 2023 MAP and APA statistics.EY

Doug McHoney (PwCâ��s International Tax Services Global Leader) is joined by Rohit Kumar, PwCâ��s National Tax Co-leader and former deputy chief of staff to Senator Mitch McConnell (R) to discuss the US election results. Doug and Rohit cover what the republican-controlled House, Senate and Presidency means for tax reform, why 2025 will be a year fo…

A review of the week's major US international tax-related news. In this edition: Republican US election sweep likely means TCJA extension via reconciliation, BEPS 2.0 project uncertainty – Final IRS Section 987 FX gain / loss regulations release before year-end – IRS comments on new passthrough field unit organization – IRS will permit digital asse…

Doug McHoney (PwCâ��s International Tax Services Global Leader) is joined by Pieter Dere, Tax Partner in PwC Belgium, part of PwCâ��s International Tax and Transfer Pricing Group, and PwC Belgiumâ��s Pillar Two leader. Doug and Pieter cover the latest Pillar Two developments in Belgium, including how Belgium is incorporating the latest Pillar Two a…

A review of the week's major US international tax-related news. In this edition: US 2024 election to have major impact on US tax policy – IRS to issue PTEP, Section 987 FX guidance by year-end – US to release notice on voluntary “Amount B”.EY

A review of the week's major US international tax-related news. In this edition: US announces tax agreement negotiations with Taiwan – IRS launches new LB&I pass-through field operations unit, EY’s Jeff Erickson chosen to lead – IRS announces new FATCA relief for FFIs – US officials discuss coming changes to CAMT regs – IRS official recommends expa…

Doug McHoney (PwCâ��s International Tax Services Global Leader) is joined by Chris Desmond, PwCâ��s US Global Trade Services Leader to catch up on the latest customs and trade happenings. Doug and Chris talk about Chrisâ��s transition from a transfer pricing partner to specializing in customs and trade, the potential US tariffs environment post ele…

A review of the week's major US international tax-related news. In this edition: US House legislators urge Taiwan tax negotiation – IRS launches new LB&I passthrough field operations unit – IRS official discusses CAMT campaign – OECD releases tax report to G20 Finance Ministers and Central Bank Governors.…

Doug McHoney (PwCâ��s International Tax Services Global Leader) is joined by returning guest Steve Kohart, an International Tax Partner in PwCâ��s New York City office and former advisor to the Center for Tax Policy Administration for the OECD. They dive into Pillar Two with a refresher of the Qualified Domestic Minimum Top-up Tax (QDMTT), the Inco…

A review of the week's major US international tax-related news. In this edition: Congress out of session until mid-November despite calls to reconvene and pass necessary funding measures – Upcoming election too close to predict for both presidential and congressional races – 2024 Annual Meetings of the IMF and World Bank Group to take place in Wash…

A review of the week's major US international tax-related news. In this edition: IRS releases final IP repatriation regulations – Treasury and IRS will release technical corrections to CAMT regs – IRS final DCL regulations will clarify anti-avoidance rule – OECD issues working paper on tax arbitrage through closely held businesses.…

Doug McHoney (PwCâ��s International Tax Services Global Leader) is joined by returning guest Aaron Junge, an International Tax Partner in PwCâ��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…

A review of the week's major US international tax-related news. In this edition: US general election will have major impact on tax policy IRS to update draft digital asset reporting instructions for Form 1099-DA OECD issues FAQs on CARF EY releases comprehensive analysis of proposed CAMT regsEY

A review of this week's major US international tax-related news. In this edition: US presidential candidates reveal tax positions – Congress averts government shutdown with continuing resolution, adjourns until after election – US officials discuss CAMT – Digital asset noncustodial broker reporting guidance coming before year end – Puerto Rico init…

Doug McHoney (PwCâ��s International Tax Services Global Leader) is joined by returning guest Alex Voloshko, an International Tax Partner in PwCâ��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 broad…

A review of this week's major US international tax-related news. In this edition: US House Speaker promises “Day One” focus on corporate tax policy with Republican election sweep – IRS soon to release final Section 367(d) regs on IP repatriation – IRS final Section 987 FX regs to reserve on partnership issues – IRS guidance on BEPS Pillar One Amoun…

A review of this week's major US international tax-related news. In this edition: US Treasury issues proposed regulations on CAMT, extends penalty relief for failure to pay estimated CAMT – Treasury and IRS officials to evaluate narrowing scope of future anti-partnership basis-shifting guidance – Official offers international regulatory update – OE…

Doug McHoney (PwCâ��s International Tax Services Global Leader) is joined by returning guest Elizabeth Nelson, a Partner in PwCâ��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). Tog…

A review of this week's major US international tax-related news. In this edition: US Congress to return to Washington – IRS corrects proposed regs to permit foreign currency mark-to-market election to be made with returns filed after 19 August 2024 – USTR requests dispute settlement consultations with Canada under USMCA to address recent enactment …

A review of this week's major US international tax-related news. In this edition: US Tax Court rules taxpayer entitled to DRD, but limits foreign tax credit.EY

Doug McHoney (PwCâ��s International Tax Services Global Leader) is joined by returning guest Rebecca Lee, a Principal in PwCâ��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 deal…

A review of this week's major US international tax-related news. In this edition: IRS issues new proposed regulations that limit / modify taxpayers’ FX elections – UN Committee advances Terms of Reference for convention on international tax cooperation.EY

A review of this week's major US international tax-related news. In this edition: US economic and tax policy become focus in Presidential race – IRS issues early draft form for brokers to report digital assets sales and exchanges – IRS expanding Compliance Assurance Process program to privately held corporations, including foreign-owned – OECD rele…

Doug McHoney (PwCâ��s International Tax Services Global Leader) is joined by Janice Mays (Managing Director in PwCâ��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 electionâ��s impact on tax policy…

A review of this week's major US international tax-related news. In this edition: US Treasury and IRS issue proposed DCL regs addressing BEPS Pillar Two, other issues.EY

A review of this week's major US international tax-related news. In this edition: US Congress adjourns for August recess – Senate fails to move Tax Relief for American Families and Workers Act with international provisions – G20 / Central Bank Governors communiqué reiterates support for BEPS 2.0 project…

Doug McHoney (PwCâ��s International Tax Services Global Leader) is joined by Wade Sutton, International Tax Leader for PwCâ��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 impor…

A review of this week's major US international tax-related news. In this edition: US House begins summer recess, Senate has additional week – DC Circuit Court of Appeals reverses Tax Court; FP’s gain from inventory on US partnership disposition is foreign-source – IRS official comments on pending CAMT guidance – PTEP regulations in the ‘home stretc…

A review of this week's major US international tax-related news. In this edition: US IRS releases final Section 367(b) regs addressing cross-border triangular reorganizations, inbound nonrecognition transactions – Congress reacts to Supreme Court’s Loper Bright decision invalidating Chevron – OECD Inclusive Framework close to finalizing MLC text on…

Doug McHoney (PwCâ��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 OECDâ��s Administrative Guidance released in June 2024, including the deferred tax liability (DTL) recapture rule or five-year rule, the alloca…

A review of the week's major US international tax-related news. In this edition: IRS issues procedural final regulations on stock repurchase excise tax – IRS releases final digital asset broker reporting regs, transitional relief for certain brokers – Canada’s DST in force, US legislators react – OECD releases draft BEPS 2.0 User Guide for GloBE in…

A review of the week's major US international tax-related news. In this edition: US Supreme Court ends court deference to agency interpretations of ambiguous laws, including tax laws – US House Republican Tax Team on global competitiveness to hold first field meeting with stakeholders on 8 August, White Paper to follow – IRS will address DCL income…

Doug McHoney (PwCâ��s International Tax Services Global Leader) is joined by Nita Asher, International Tax Partner in PwCâ��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 Reducti…

A review of the week's major US international tax-related news. In this edition: US Supreme Court upholds validity of IRC Section 965 mandatory repatriation tax – US Treasury Department suspends key provisions of US-Russia Tax Treaty and Protocol – IRS issues package on certain related-party partnership basis shifting transactions – OECD/G20 Inclus…

A review of the week's major US international tax-related news. In this edition: US House Republicans eye budget reconciliation legislation in 2025 – IRS again extends penalty relief for failure to pay estimated CAMT.EY