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Cross-border Tax Talks

June 08, 2021

Explaining the explanation: Biden’s Greenbook

Doug McHoney (PwC's US International Tax Services (ITS) Leader) holds the second post-vaccine session live at the Westminster Studios with Pat Brown (PwC WNTS Policy Co-leader) to discuss President Biden’s FY 22 Budget and the much anticipated and related explanations of such proposals, also known as the Treasury Green Book. Doug and Pat cover, among other proposals: increasing the US corporate income tax rate from 21% to 28%; increasing the global intangible low-taxed income (GILTI) tax rate to 21%; removing the qualified business asset investment (QBAI) provision; repealing the deduction for foreign derived intangible income (FDII); replacing the Base Erosion and Anti-Abuse Tax (BEAT) with a Stopping Harmful Inversions and Ending Low-tax Developments (SHIELD) provision; restricting deductions of excessive interest for disproportionate borrowing in the US; the status and likelihood of the OECD’s Pillars One and Two; and what companies should consider as potential tax legislation becomes more likely.


  • 2:30 - What is the ‘Green Book’?
  • 5:30 - How does the Green Book become law?
  • 7:30 - Where is the Administration heading with the corporate tax rate?
  • 11:30 - Why is it important for US-headquartered companies to be competitive in foreign markets outside the United States?
  • 17:00 - What is the reasoning behind repealing FDII?
  • 23:00 - What are some of the sweeping changes made to the GILTI regime?
  • 29:30 - How do these proposals affect what some consider to be a territorial tax system under TCJA?
  • 31:30 - What are the proposed changes to Section 265?
  • 35:30 - What is the new SHIELD regime that is being proposed to replace the BEAT?
  • 40:30 - How similar are this Green Book’s interest deductions proposals to those released during the Obama Administration?
  • 43:30 - What is the Administration’s view on limiting inversions?
  • 45:30 - What is the 15% minimum tax on book income?
  • 47:30 - How does the new proposal limiting foreign tax credits on hybrid entities work?
  • 49:30 - What are the new changes to the  taxation of foreign fossil fuel income?
  • 51:00 - How does the prospects of an OECD global minimum tax interact with the US tax proposals?


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Doug McHoney

International Tax Services Co-Leader, PwC US

Geoff Jacobi

ITS, Knowledge Management Managing Director, PwC US

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