Final Section 965 regulations: Amended tax returns ahead?

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Final Section 965 regulations: Amended tax returns ahead?

FromCross-border Tax Talks

ratings:

Length:

38 minutes

Released:

Feb 18, 2019

Format:

Podcast episode

Released:

Feb 18, 2019

Format:

Podcast episode

Titles in the series (100)

PwC specialists share insights and perspectives on key issues impacting the ever-changing tax landscape. Our podcasts aim to provide quick, easy and up-to-date tax developments to help you stay current and competitive in today's challenging business environment. Listen to episodes at your convenience via your desktop computer or smart device.

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European Union State aid: a $13 Billion (and counting) issue! by Cross-border Tax Talks
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Widgets on hold: Shedding light on sovereign wealth and pension funds by Cross-border Tax Talks
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Cross-border tax talks: Tax regulations: behind the scenes by Cross-border Tax Talks
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Section 163(j) - A brave new world for partnerships by Cross-border Tax Talks
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Cross-border tax talks: International tax provisions by Cross-border Tax Talks
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Final Section 965 regulations: Amended tax returns ahead? by Cross-border Tax Talks
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A Fortune 50 Tax VP's perspective on tax reform by Cross-border Tax Talks
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FDII shades of gray: 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) regulations under Section 250. Among other topics, they discuss how FDII interplays with GILTI, and how the FDII proposed regulations would apply to property transactions, component manufacturing, intangibles, and services. by Cross-border Tax Talks
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Update on global tax reform: ATAD, MLI, DAC6 by Cross-border Tax Talks
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The global tax environment from an OECD perspective by Cross-border Tax Talks
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US Tax Reform: Understanding Treasury's Role by Cross-border Tax Talks
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The CARES Act: a primer for cross-border tax professionals by Cross-border Tax Talks
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The DRD 245A regs: Did the donut hole eat the donut? by Cross-border Tax Talks
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US Tax Reform: GILTI as charged! by Cross-border Tax Talks
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Key findings: Sec 965 Proposed Regs by Cross-border Tax Talks
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Cross-border tax talks: Treasury considerations after tax reform by Cross-border Tax Talks
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Around the geopolitical (and tax) world in 30 minutes by Cross-border Tax Talks
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Trading places: the intersection of tax and trade by Cross-border Tax Talks
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Your foreign tax credits after tax reform - a basket case? by Cross-border Tax Talks
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Temas candentes: Hot issues in Mexican tax by Cross-border Tax Talks
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Behind the Curtain: The Joint Committee on Taxation by Cross-border Tax Talks
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Anti-hybrid rules: the forgotten reform provisions by Cross-border Tax Talks
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DAC6 Update: the latest EU disclosure rules: 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 background of DAC6 and how it compares to the BEPS Action Item 12 concerning country-by-country reporting; when taxpayers will need to comply with the DAC6 reporting rules; how individual countries will need to implement DAC6; the differences between a 'taxpayer' and an 'intermediary' in the context of DAC6; the responsibilities of taxpayers and intermediaries; which transactions are considered 'reportable transactions'; potential penalties for not complying with the DAC6 reporting requirements; the potential downsides for reporting transactions that may not be considered 'reportable transactions' under DAC6; and final words of wisdom for by Cross-border Tax Talks
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A practitioner’s brief history of international tax in the US by Cross-border Tax Talks
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Invalidity: When and why are tax regulations invalid? by Cross-border Tax Talks
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Tax Reform with a slice of Swiss by Cross-border Tax Talks
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Merging lanes: key MA and international tax considerations after TCJA by Cross-border Tax Talks
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We got the BEAT: US Tax Reform Regulations by Cross-border Tax Talks
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Branch FX: Were those Section 987 regulations final? by Cross-border Tax Talks
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Pillar Two Data Strategy: Play ball!!!: Doug McHoney (PwC's US International Tax Services Global Leader) is with Anthony Sciarra, a Principal in PwC’s Tax Reporting and Strategy Practice and the Global Pillar Two Data Strategy leader, to discuss the importance of a Pillar Two Data Strategy. Doug and Anthony detail what taxpayers should be doing today to stay ahead of Pillar Two’s complexity, specifically highlighting: data sourcing, data forecasting, qualifying for the CbC Transitional Safe Harbor, considerations for both an insourcing & outsourcing model, existing technology solutions, and the importance of a centralized rules calculation. by Cross-border Tax Talks
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As the world turns: Macroeconomic trends: Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s International Tax Conference in Dana Point, California with Dr. Alexis Crow, PwC’s Geopolitical Investing Practice Leader. Doug and Alexis discuss the recession outlook and economic activity, the impact of inflation, central banking policy, including interest rates, commercial real estate and financial stability, currencies and the future of the US Dollar, energy transition, the US election outlook, and outlooks for some significant economies, including Japan, India, Singapore, Brazil, the Middle East, and Europe. by Cross-border Tax Talks
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Brazil Tax Reforms: muito complicado!: Doug McHoney (PwC’s International Tax Services Global Leader) is in São Paulo, Brazil for the first Latin American recording of the CBTT with PwC Brazil’s International Tax Leader Dr. Romero Tavaras. Doug and Romero discuss what makes Brazil’s tax system so unique – from its transfer pricing rules to its full inclusion regime. They also dive into expected Brazilian tax changes, the many acronyms that make up the indirect tax system, Pillar One, and what effect Pillar Two will have on Brazil’s taxpayers. by Cross-border Tax Talks
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US Tax Policy: Chairman Dave Camp: Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s International Tax Conference in Dana Point, California with former House Ways & Means Chairman Dave Camp, now senior policy advisor in PwC’s Washington National Tax Services. Doug and Chairman Camp discuss his political career, drivers behind US tax policy, how Congress negotiates tax legislation, the expiring provisions in the Tax Cuts & Jobs Act (TCJA), the prospects of Congress implementing Pillar Two in the years ahead, and how companies can get involved in the tax legislative process. by Cross-border Tax Talks
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Geopolitics Unraveled: Trends for 2024: In this episode of Cross-Border Tax Talks, Doug McHoney interviews Craig Stronberg, a Senior Director in PwC's Intelligence Team, about major geopolitical trends impacting business leaders and the operating environment. They discuss topics such as protectionism, the US-China rivalry, distrust, the shift in global power, tech disruption, labor, and the Middle East. They also highlight the importance of business leaders taking stock of lessons learned from the COVID-19 pandemic and the potential risks associated with the ongoing conflict in Ukraine. by Cross-border Tax Talks
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US Guidance Update: Pillar Two and more: On this episode, Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Wade Sutton. Wade is PwC’s Washington National Tax Service’s ITS Leader, a former adjunct professor of international tax at Georgetown University's Law Center, and former Deputy International Tax Counsel, US Treasury. Doug and Wade discuss what drove them to international tax as a career (spoiler: job security) before diving into recent US tax guidance. They discuss the recent foreign tax credit (FTC), corporate alternative minimum tax (CAMT) and Previously taxed E&P (PTEP) notices. They also discuss the interaction of Pillar Two with the FTC rules, dual consolidated loss (DCL) rules, and CAMT. Doug and Wade wrap up by looking ahead to guidance we might see in 2024. by Cross-border Tax Talks
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Disequilibrium: The new geopolitical and macroeconomic landscape: 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. by Cross-border Tax Talks
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Final Section 965 regulations: Amended tax returns ahead?

Final Section 965 regulations: Amended tax returns ahead?

Titles in the series (100)

More Episodes from Cross-border Tax Talks