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Cross-border tax talks
Hosted by Doug McHoney, PwC's Global International Tax Services Leader, the Cross-border Tax Talks Series provides listeners with the latest trends in taxation. Various PwC specialists are featured and share insights on key issues impacting the ever-changing tax landscape.
New installments are released regularly and available for subscription at Apple Podcasts, Spotify, Overcast, and TuneIn. You can also listen at your convenience via your desktop computer or smart device.
A regulatory balancing act: Recent US guidance
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Wade Sutton, International Tax Leader of PwC’s Washington National Tax Services practice and guest host of Cross-border Tax Talks. After Wade reflects on his previous experience at the US Treasury Department, he and Doug discuss four proposed regulation packages under the One Big Beautiful Bill Act (OB3): expense allocation for net CFC tested income (NCTI) and foreign-derived deduction-eligible income (FDDEI), FDDEI eligibility changes, CFC pro rata share rules, and repeal of the one-month deferral election. They examine foreign tax credit limitations, overall domestic loss exposure, M&A drafting and tax-year elections, and transition relief. The conversation also covers reconciliation prospects, regulatory comment periods, Loper Bright’s influence on Treasury’s approach, and anticipated guidance on foreign sales branches and foreign-controlled CFCs.
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Contact us
Doug McHoney
International Tax Services Global Leader, PwC US
I’m the global leader of PwC’s International Tax Services practice — and a husband, dad to canines, mentor, mentee, vlogger and podcaster.
Geoff Jacobi
ITS, Knowledge Management Managing Director, PwC US
United States
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