Cross-border Tax Talks

December 14, 2021

Tax reform: Digging in, before building back

Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Jeff Endress, US Outbound Tax Practice leader. They discuss the House-passed Build Back Better (BBB) bill, delayed effective dates, Section 163(n), foreign tax credits, country-by-country, the complexity of global tax, Pillar Two, uncertainties in the deals market, and the future of tax reform.


  • 2:50 - With the BBB bill sitting in the Senate, we can look back at the 2017 tax reform to compare it to tax reform now. What aspects of the new bill are receiving the most attention in the market?
  • 9:40 - What are the basics of Section 163(n) and what has it changed? How would it affect external debt and internal capital structures if enacted as currently drafted?
  • 18:15 - Reform will bring significant changes to the foreign tax credit regime. How would the idea of moving to a country-by-country basis for individual baskets impact taxpayers, in particular public companies with deferred tax assets?
  • 28:10 - What are multinational companies looking at with the oncoming complexity of foreign tax credit limitation?
  • 31:25 - How do global tax developments triangulate into the new multinational tax experience? What can companies expect from Pillar Two changes?
  • 35:00 - The deal market has been extremely hot and shows no sign of cooling off. What kind of uncertainties are we seeing, and how are you dealing with that?
  • 39:05 - Over the course of the next three years, there will be no shortage of things to talk about at Cross Border Tax Talks with the BBB Bill and Pillar Two coming down the road - are we going to see another round of tax reform every four years?

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Doug McHoney

International Tax Services Global Leader, PwC US

Geoff Jacobi

ITS, Knowledge Management Managing Director, PwC US

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