Cross-border Tax Talks

One big beautiful podcast: Part 2

Doug McHoney (PwC’s International Tax Services Global Leader) is joined on June 24, 2025, by Pat Brown, an International Tax Partner and Co-Leader of PwC’s Washington National Tax Services practice. Pat previously served as the US Treasury’s Associate International Tax Counsel and has been a frequent guest on the podcast. Doug and Pat start where they left off discussing 'One Big Beautiful Bill' (OB3), in wake of the US Senate Finance Committee Chairman's Substitute Amendment. They discuss the next steps in the legislative timeline including the impending July 4th deadline, the impact of the Byrd rule, as well as the many changes to both the business and international provisions. They focus on the major changes to Section 899, global intangible low-taxed income (GILTI), foreign derived intangible income (FDII), and the base erosion and anti-abuse tax (BEAT).

• 00:00 – Introduction and Pat Brown’s return as guest 
• 01:30 – US Senate Finance Committee Chairman's Substitute Amendment 
• 03:00 – Legislative timeline to enact tax legislation under reconciliation 
• 07:30 – What is the ‘Byrd bath’ rule in the Senate 
• 12:15 – How did the Section 899 provision change from the House proposal to the Senate proposal 
• 15:15 – How will the undertaxed profits rule (UTPR), digital services tax (DST), and diverted profits tax (DPT) be treated under the Senate proposal 
• 20:00 – The TCJA orphans – Section 174, Section 163(j), and Section 168(k) 
• 23:30 – From a policy perspective: How did the Senate approach tax changes 
• 26:15 – What were the changes to the GILTI or Net CFC Tested Income (NCTI) 
• 30:15 – What were the changes to FDII or Foreign-Derived Deduction Eligible Income (FDDEI) 
• 33:15 – What were the changes to the BEAT rules 
• 38:00 – How was the BEAT scored now that includes a high tax exception 
• 40:15 – Other international tax changes – CFC look-through rule and elimination of One-month deferral (CFC tax year election) 
• 42:00 – Key sticking points between the House and the Senate in reaching a final bill 

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