Cross-border Tax Talks

June 22, 2022

100th Episode Special: The evolution of global structuring

Doug McHoney (PwC's International Tax Services Global Leader) is joined by Mike Urse, current International Tax Partner and former US International Tax Services Leader for the 100th episode of the Cross Border Tax Talks podcast. Doug and Mike discuss the changing world of international taxation, focusing on the current status of holding companies, finance companies, and Intangible property companies. Mike provides insights and analysis from almost 40 years of international tax experience and sheds some light on the future state of play.

Timestamps:

  • 3:15 - In Mike’s opinion does the current moment represent the biggest transformation in International Tax?
  • 5:30 - Starting with Holding Companies, it’s very common historically for US Multinational companies to set up an investment company to hold international operations. Why was this the case, and how has it changed over the years?
  • 10:00 - What are some of the challenges inherent to holding companies that taxpayers need to think through?
  • 15:00 - Pillar Two and the income inclusion rule - is that another reason to consider whether the holding company is fit for purpose?
  • 18:00 - Moving on to financing companies - we’ve seen a trend toward more substantive financing activities - lending, hedging, cash pooling - what are some of the trends we’re seeing from both a ‘borrower/lender’ context?
  • 23:30 - Is the US a good jurisdiction for lending?
  • 26:00 - And finally, intellectual property companies - what are the trends, and how does Pillar Two fit in?
  • 31:30 - Why should companies consider moving IP during the Pillar Two transition period?
  • 34:00 - What are the potential Pillar Two implications from a post deal restructuring?

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Speakers

Doug McHoney

International Tax Services Global Leader, PwC US

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Doug McHoney

Doug McHoney

International Tax Services Global Leader, PwC US

Geoff Jacobi

Geoff Jacobi

ITS, Knowledge Management Managing Director, PwC US

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