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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.
In Jeopardy: Sovereign wealth funds and Section 892
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Nils Cousin, an international tax partner in PwC’s Washington National Tax Services Practice, for his fourth appearance on the show. Doug and Nils discuss Nils’s April 2024 Jeopardy experience before pivoting to the 1916-era Section 892 exemption: how foreign governments, sovereign wealth funds, and public pension funds use it, and how ‘commercial activity’ and ‘controlled commercial entity’ rules can taint the benefit. They unpack the December 2025 regulation package, highlighting what was finalized (including an inadvertent-activity cure period, the qualified partnership exception, and FIRPTA taint relief) and what remains proposed, especially a framework that presumptively treats many debt acquisitions and workouts as commercial activity. The episode closes with the regulation process, effective-date mechanics, and a January 18 Treasury Secretary tweet, leaving us wondering whether market feedback might drive revisions.
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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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