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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.
Pillar Two SESHion: ‘Simplified’ safe harbour
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Steve Kohart, a New York City-based international tax partner at PwC and former advisor to the OECD’s Center for Tax Policy and Administration. Doug and Steve discuss the January side-by-side agreement’s implications for US-parented multinationals, why Pillar Two remains relevant through QDMTTs, and how the CBCR transitional safe harbor bridges to the permanent simplified ETR safe harbor. They unpack what ‘simplified’ really means: financial accounting standards, denominator and numerator adjustments, deferred tax ‘bad DTLs,’ and the practical reality of a third set of books. The conversation also covers JV complications, Chapter 6 M&A/reorg rules, transition provisions (9.1.1–9.1.3) and excess negative taxes, new flexibility for return-to-provision adjustments, integrity rules, and what guidance and compliance planning teams should prioritize next.
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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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