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April 10, 2020

The CARES Act: a primer for cross-border tax professionals

Doug McHoney (PwC's US International Tax Services Leader) and Mike DiFronzo (PwC's Washington National Tax Services ITS Leader) do a deep dive into the recently enacted CARES Act. Doug and Mike discuss: the general structure of the tax provisions included in the CARES Act; details of the five-year carryback for 2018, 2019, and/or 2020 Net Operating Losses (NOLs); how NOLs interact with Foreign-Derived Intangible Income (FDII), Global Intangible Low-Taxed Income (GILTI), Foreign Tax Credits (FTCs), and the Section 965 'toll charge'; how refund procedures used in the 2008 crisis may guide current and upcoming refund procedures; how the CARES Act amends the Section 163(j) interest expense limitation; why entities making NOL and/or Section 163(j) adjustments should model their changes due to the potential implication of the Base Erosion and Anti-abuse Tax (BEAT); and how the CARES Act amended Alternative Minimum Tax (AMT) acceleration and Qualified Improvement Property (QIP) bonus depreciation.

Duration: 37:54

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Doug McHoney

International Tax Services Leader, PwC US

Geoff Jacobi

ITS, Knowledge Management Managing Director, PwC US

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