35 min listen
Sweet Child O'Mine: Inbounding Intangibles to the US
Sweet Child O'Mine: Inbounding Intangibles to the US
ratings:
Length:
42 minutes
Released:
Jun 7, 2023
Format:
Podcast episode
Description
Doug McHoney (PwC's International Tax Services Global Leader) is joined by Aaron Junge, PwC National Tax Services International Tax Partner, and former Tax Counsel for the House of Representatives during the enactment of the Tax Cuts and Jobs Act. They discuss the historical perspective of the Section 367(d) rules beginning back in 1984, the recent regulations, and how we got here. Doug and Aaron touch on Section 367(d)’s original intended purpose, how the changes that occurred during TCJA changed intangible property (IP) ownership for US MNC’s (the carrot and the stick metaphor), the possible tax treatments of the repatriation of IP, the applicability dates, and how taxpayers can prepare, while considering Pillar Two, among other areas.
Released:
Jun 7, 2023
Format:
Podcast episode
Titles in the series (100)
European Union State aid: a $13 Billion (and counting) issue! by Cross-border Tax Talks