Pillar Two Administrative Guidance: More details, more questions

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

45 min listen

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

35 min listen

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

44 min listen

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

41 min listen

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

47 min listen

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

47 min listen

Sustainability and Transparency for Tax Professionals: In this podcast episode, Doug McHoney, PwC’s International Tax Services Global Leader, interviews Heather Horn, PwC's Assurance National Thought Leader and host of the twice-weekly PwC Accounting Podcast. Doug and Heather discuss sustainability reporting and its increasing importance in the business world. They cover various regulations and standards, such as the EU’s Corporate Sustainability Reporting Directive (CSRD), and the potential intersection between sustainability reporting and tax transparency. Doug and Heather note the similarities between CSRD and other recent reporting requirements, like Pillar Two and the EU’s Foreign Subsidies Regulation (FSR). They also highlight the challenges and considerations for companies as they deal with new stakeholders and navigate the new reporting requirements. by Cross-border Tax Talks

34 min listen

Pillar Two: how safe is the safe harbor?: Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Steve Kohart for our first podcast in PwC’s New York studio. Steve is a PwC international tax partner based in New York, and a former adviser for the OECD Center for Tax Policy and Administration. Doug and Steve discuss the OECD’s latest Pillar Two Administrative Guidance, which was published December 18, 2023 and primarily covers the transitional country by country Safe Harbor. More specifically, Doug and Steve address how jurisdictions will implement the guidance, purchase price accounting adjustments, consistent use of data, hybrid arbitrage arrangements, the allocation of CFC taxes, and whether the OECD will provide additional guidance in 2024. by Cross-border Tax Talks

46 min listen

Gen AI in Tax: a new frontier: Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s Tax Leadership Conference in breezy Orlando with Dom Megna, a New York-based tax partner leading PWC's US Tax Reporting and Strategy Practice. Doug and Dom discuss Artificial Intelligence (AI) and its place in tax. They focus on four areas - what is conversational AI, machine learning, deep learning, and generative AI (a subset of deep learning). They also cover some impacts of AI: AI for tax practitioners, how AI will affect people’s jobs, data opportunities and architecture, Pillar Two, responsible AI, and the ROI of AI. by Cross-border Tax Talks

38 min listen

Taxing FX of Branches: the new Section 987 regulations: Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Rebecca Lee (WNTS ITS Partner) in PwC’s Washington, DC studio for the 140th (and Rebecca’s) episode of the Cross-Border Tax Talks podcast. Rebecca, a frequent guest on the podcast, specializes in financial transactions and digital assets. Doug and Rebecca discuss the history and intent of Section 987, which is generally to address the taxation of foreign exchange gains/losses from a foreign branch operating in a different functional currency than its home office. The rules started out relatively simply at three sentences, but since enactment we’ve received 100s of pages of regulations. Doug and Rebecca discuss how the layers of complication led to confusion and concerns over policy and administrability. This background is critical to understanding the challenges companies are facing today with the November 2023 proposed regulations. Doug and Rebecca dissect by Cross-border Tax Talks

44 min listen

UK Pillar Two: Painting while the paint dries: Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Matt Ryan at PwC’s Global Tax Symposium in Rome. Matt is a London-based international tax partner and PwC UK’s Pillar Two Leader. Doug and Matt revisit the UK Pillar Two rules for the third time, but now from an enacted law perspective. While the rules are set to apply from the beginning of 2024, the United Kingdom faces an interesting challenge as one of the early adopters of Pillar Two, with enacted legislation, followed by additional OECD guidance. Doug and Matt discuss the tricky task for UK legislators of ‘painting while the paint still dries’ (i.e., enacting legislation while the OECD guidance is still changing) and some of the key differences that need to be addressed as a result of the subsequent OECD guidance, as well as still-expected guidance in 2023 and beyond. Doug and Matt discuss from a practical perspective how UK-parented taxpayers are preparing for by Cross-border Tax Talks

36 min listen

Pillar Two: Policy, politics and interaction with Pillar One: Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s Global Tax Symposium in Rome, where he’s joined by Will Morris. Will is PwC’s Global Tax Policy Leader, and on Will’s last visit to the podcast, he covered FSR, the Foreign Subsidies Regulation. On this podcast, an exciting and familiar topic - Pillar Two! Doug and Will discuss generally how the Pillar Two process has been going. They wonder how tax authorities and courts will administer and adjudicate in their jurisdictions, and what will become of the potential FAQs and future administrative guidance from the OECD. They then discuss the recent EC guidance, and whether countries will be able to bring in the OECD guidance retroactively. Finally, Doug and Will touch on how business have participated thus far in the process. by Cross-border Tax Talks

38 min listen

Pillar One: Policy, politics and interaction with Pillar Two: Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s Global Transfer Pricing Conference where he’s joined by Giorgia Maffini. Giorgia is part of PwC’s Global Transfer Pricing team in London and was previously the Deputy Head of the Tax Policy and Statistics Division at the OECD. Doug and Giorgia discuss why taxpayers should care about Pillar One, starting with the basics - what is Pillar One and how does it work with Pillar Two? They discuss the complexities, scope and impacts of both Amount A and Amount B. Also the timing, economic impact, and what’s next. Finally, they address what might happen with digital services taxes and what companies should do next. by Cross-border Tax Talks

41 min listen

Pillar Two Safe Harbors: The CbCR journey: Doug McHoney (PwC’s International Tax Services Global Leader) is joined by David Ernick, a Principal with PwC’s Washington National Tax Services Transfer Pricing Practice and former Associate International Tax Counsel at the US Treasury Department, at PwC’s Global Transfer Pricing Conference in San Diego, California. They discuss Country-by-country reporting (CbCR) transitional safe harbor rules, including the safe harbor tests, exclusions to the rules, the difference between the safe harbor rules and the full GLoBE rules, as well as whether a CbCR is ‘qualifying’. Doug and David also discuss the history and implementation of public CBCR. by Cross-border Tax Talks

42 min listen

On notice: US developments and Moore hype: Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s Tax Leadership Conference in breezy Orlando with Pat Brown, frequent pod guest and co-leader of PwC’s Washington National Tax Services. They discuss US tax updates, including the status and fate of the Tax Cuts and Jobs Act (TCJA); the future of Section 163(j); notices and guidance from Treasury, including the recent Section 174 notice 2023-63; FTC relief notice, and what to anticipate in the coming months and years with respect to foreign tax creditability; what’s included and what’s not included under the corporate alternative minimum tax (CAMT); Section 367(b) ‘Killer B’ regulations; and the Moore case. by Cross-border Tax Talks

45 min listen

Trick or treat(y): An update on US treaties: Doug McHoney (PwC’s International Tax Services Global Leader) is back in Westminster Studios in St. Louis, Missouri with Nils Cousin, a Washington, D.C. based International Tax Services Principal specializing in US inbound taxation. Together they discuss tax treaties, mutual agreement procedures, the concept of competent authority, the treaty process in the US, recent US tax treaty activities, treaty shopping, the USMCA Trade Agreement, and the future of tax treaties in the United States. Among the treaties and agreements discussed are US treaties and agreements with Chile, Croatia, Hungary, Taiwan, and Russia. by Cross-border Tax Talks

46 min listen

Moore v. US: Constitutionality of international tax: Doug McHoney (PwC's International Tax Services Global Leader) and Wade Sutton (former Deputy International Tax Counsel for the US Treasury and newly appointed ITS leader of PwC’s Washington National Tax Practice) are back in Washington, D.C. to discuss the recent Supreme Court grant of certiorari for the Moore v. US case. Doug and Wade go back to their law school days to break down the Moore case, starting with the facts, procedural history, and the potential implications if Section 965 is ruled unconstitutional, including direct taxation, indirect taxation, subpart F, Section 245A, GILTI, and, as always, Pillar Two. by Cross-border Tax Talks

29 min listen

Poutine Routine: Canada’s Pillar Two, DSTs, with G(AA)Ravy on top: Doug McHoney (PwC's International Tax Services Global Leader) and Ken Buttenham meet up in PwC’s Washington, D.C.. studio. Ken leads PwC Canada’s International Tax Practice from Toronto. Doug and Ken kick off with a discussion on Doug’s favorite Canadian food, then dive into the Canadian Pillar Two proposals, discussing the Global Minimum Tax Act (GMTA), UTPR, IIR, QDMTT, compliance, the GloBE Information Return, and tax incentives. They also cover digital services taxes (DSTs), the excessive interest and financing expenses limitation (EIFEL) rules, and the Canadian General Anti-Avoidance Rule (GAAR). by Cross-border Tax Talks

39 min listen

Pillar Two in Hong Kong: Not yet a sticky wicket?: Doug McHoney (PwC's International Tax Services Global Leader) and Jesse Kavanaugh (PwC Hong Kong’s Tax Reporting & Strategy Leader) met up at PwC’s AsiaPac Global Tax Symposium in Singapore. Jesse is an International Tax Partner in Hong Kong and has been leading the region’s Pillar Two tax efforts. They discuss the state of play of Pillar Two in Hong Kong, trends regarding safe harbours and data collection, modeling and calculations challenges, the centralized and decentralized approaches to Pillar Two inherent to the region, and the Hong Kong legislative process. They also touch on the addition of Hong Kong to the EU’s ‘grey list’ and the recent introduction of the Foreign Source Income Exemption (FSIE) Regime for Passive Income. by Cross-border Tax Talks

37 min listen

Pillar Two and Financial Services: What’s the deal?: Doug McHoney (PwC's International Tax Services Global Leader) is joined by first-time guest Winnie Tang, International Tax Partner in PwC’s Financial Services practice in New York. Doug and Winnie take a rapid fire tour of the Financial Services and Deals space in light of the Pillar Two Transition Period, touching on the definitions of funds, REITs, excluded entities, management company structures, POPEs, Pillar Two in the Deals space, and many more particularities taxpayers should be aware of. by Cross-border Tax Talks

36 min listen

Pillar Two in South Korea: Effective dates and much more: Doug McHoney (PwC's International Tax Services Global Leader) is at PwC’s AsiaPac Tax Symposium in Singapore. He is joined by Michael Kim, a PwC International Tax Partner and South Korea’s Outbound Tax Leader. Doug and Michael discuss South Korea’s enactment of Pillar Two, paying particular attention to effective dates, likely legislative actions, the incorporation of future guidance, how taxpayers are preparing for Pillar Two, Safe Harbours, data collection, and covered taxes. by Cross-border Tax Talks

30 min listen

EU’s Foreign Subsidies Regulation: State Aid goes global: Doug McHoney (PwC's International Tax Services Global Leader) is at PwC’s Global Financial Services Tax Leaders Meeting in Paris where he is joined by Will Morris, recently named PwC’s Global Tax Policy Leader. Together, they dive into the European Union’s Foreign Subsidies Regulation (FSR). They start with the origin story, how it intersects with State Aid, how taxpayers can be compliant, the necessity for collecting and saving data and information, consequences for failing to comply, and the challenges that taxpayers will face in the coming years, whether or not they currently do business in the European Union. by Cross-border Tax Talks

41 min listen

Sweet Child O'Mine: Inbounding Intangibles to the US: 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. by Cross-border Tax Talks

42 min listen

Freshly Served: Germany’s latest Pillar Two Draft: Doug McHoney (PwC's International Tax Services Global Leader) is joined in Madrid by Arne Schnitger, International Tax Partner with PwC Berlin and host of the German podcast Frisch Serviert (Freshly Served). They dive into the German legislative process, compliance and reporting, the German QDMTT, deviations from the OECD Model Rules, as well as the interaction with the US GILTI regime. They also discuss Arne’s recent article, “Does the 'Initial Phase Relief' Make the EU’s Pillar Two Directive Invalid? by Cross-border Tax Talks

40 min listen

Alphabet soup: A taste of EU tax: Doug McHoney (PwC's International Tax Services Global Leader) is joined in Madrid by Edwin Visser, PwC’s European Tax Policy Leader. Prior to joining PwC, Edwin was the Deputy Director General for Tax Customs Policy and Legislation and Director for Direct Taxes at the Dutch Ministry of Finance. One of the real challenges for tax professionals and advisors is the sheer volume of tax proposals from the European Union. Edwin and Doug discuss the numerous EU tax proposals, including the Carbon Border Adjustment Mechanism (CBAM), the Foreign Subsidies Regulation (FSR), Green Energy Credits, ATAD3. They also cover the EU’s legislative process, flashback to the Common Consolidated Corporate Tax Base (CCCTB), then tackle Business in Europe: Framework for Income Taxation (BEFIT), the SAFE project, and the Debt-equity bias reduction allowance (DEBRA). They cap the episode with a check in on Pillar One and Pillar Two. by Cross-border Tax Talks

48 min listen

Pillar Two: The UK’s latest installment: Doug McHoney (PwC's US International Tax Services Global Leader) hosts Matt Ryan, London-based International Tax Partner and leader of PwC’s UK Pillar Two Ready Team. Doug and Matt discuss the second draft of the UK’s Pillar Two legislation, the probable timing of enactment, the accounting implications, the UK’s Qualified Domestic Minimum Top-up-Tax, and some of the ‘deviations’ in the UK rules. by Cross-border Tax Talks

42 min listen

Threading the Needle: Pillar Two and the IRA’s Green Energy Credits: Doug McHoney (PwC's US International Tax Services Global Leader) is joined by Pat Brown, seven-time veteran of the podcast, and co-leader of PwC’s WNTS practice. Pat has previously worked in the private industry for 16 years, including several years as a VP of tax and director of tax policy. After Pat chooses his most and least favorite CBTT podcasts, Doug and Pat discuss green energy credits, the Pillar Two Model Rules and administrative guidance, how the US and UK R&D credits compare under Pillar Two, refundable credits, transferable credits, the equity investment inclusion election, and qualifying flow-through tax benefits. by Cross-border Tax Talks

45 min listen

Pillar Two: A Japanese perspective: Doug McHoney (PwC's US International Tax Services Global Leader) is joined by Shin Yamaguchi at PwC’s 2023 International Tax Conference. Shin is a Tokyo-based International Tax Partner, where he leads PwC Japan’s Inbound Tax Practice. Doug and Shin discuss Japan’s latest tax developments, focusing on the Pillar Two rules (of course!), specifically, UTPR, IIR, Safe Harbours, QDMTT, the GloBE Information Return and effective dates. They also discuss the Japanese legislative process.Since the recording of this podcast Japan has enacted their 2023 Tax Reform Bill which includes the Pillar Two Income Inclusion Rule which applies on or after April 1, 2024. by Cross-border Tax Talks

38 min listen

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

39 min listen

Pillar Two Readiness: Complex data and complex challenges: Doug McHoney (PwC's US International Tax Services Global Leader) is back in Westminster Studios with Kate Miller, a Director in PwC’s Tax Reporting and Strategy Practice. Doug and Kate discuss what is meant by Pillar Two operational readiness and PwC’s Data Input Catalog, including the data requirements, the necessity of resources, the Data Input Catalog, safe harbours, ERP and enterprise systems, the importance of working as a team, how software tools can help, and the power of a centralized rules engine.PwC’s Data Input Catalog by Cross-border Tax Talks

40 min listen

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Pillar Two Administrative Guidance: More details, more questions

Pillar Two Administrative Guidance: More details, more questions

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