Wade Sutton is joined by Pat Brown to take a deeper dive into the future of Pillar Two, focusing on the G7’s ‘side-by-side' agreement.
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In this podcast, PwC’s David Ledure, Tanja Keser and Alex Xiang discuss the complex interplay between financial transactions and operational transfer pricing, including how activities above and below the EBIT line interact.
Doug McHoney is joined by Wade Sutton, a principal who leads the international tax team in PwC’s Washington National Tax Services practice, to discuss the One Big Beautiful Bill Act (“OB3”) and its impact on outbounds.
Doug McHoney is joined by Nita Asher, an international tax principal in PwC’s Washington National Tax Services practice, to discuss the One Big Beautiful Bill Act (“OB3”) and its impact on inbounds.
Doug McHoney is joined by Raza Janjua, a Director in PwC’s ITS practice in New York and author of a recent article on Pillar Two hybrid arbitrage arrangements. Doug and Raza discuss the BEPS Action 2 origins and ATAD 2 implementation; how Pillar Two’s simplified safe harbors spawned detailed hybrid arbitrage rules.
Doug McHoney is joined by Craig Stronberg, and they discuss changes to US global policy and protectionism; the rise of new global powers and alliances; the growing divide between developed and developing countries regarding global tax policy; the debate over globalization’s benefits; and the current trade environment.
This episode focuses on UK transfer pricing developments, including proposed reforms to transfer pricing, permanent establishment, and the Diverted Profits Tax.
Doug McHoney is joined by Mike Urse and Calum Dewar, and they discuss the dynamic nature of international tax and the intellectual curiosity that drew them to the profession.
Doug McHoney Pat Brown discuss the newly enacted OB3 reconciliation law, focusing on its permanent corporate and individual tax provisions, the recalibration of bonus depreciation, Section 174 expensing and Section 163(j); the Senate’s redesign of GILTI, FDII and BEAT; Inflation Reduction Act rollbacks; Treasury’s...
Doug McHoney and Jesse Kavanaugh discuss the uneven rollout of Pillar Two across nine Asia-Pac jurisdictions; China, India and US uncertainties; Hong Kong’s Pillar Two legislation and HKMTT design; and much more.
Doug McHoney Pat Brown start where they left off discussing 'One Big Beautiful Bill' (OB3), in wake of the US Senate Finance Committee Chairman's Substitute Amendment. They discuss the next steps in the legislative timeline including the impending July 4th deadline, the impact of the Byrd rule, as well as the many...
Doug McHoney Pat Brown discuss the legislative and international tax implications of the 'One Big Beautiful Bill', including its procedural path through US Congress under budget reconciliation, and its implications for both domestic and cross-border taxpayers.
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