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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.
When regs lose their deference: Three cases rewrite the tax playbook
Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Laura Williams, an international tax partner in PwC’s Washington National Tax Services office and former branch chief in the IRS Office of Chief Counsel. Doug and Laura discuss the role of Treasury regulations, Section 7805(a), and the post-Loper Bright limits on agency deference and delegated authority. They explain why TCJA’s mismatched effective dates created a ‘donut hole’ and examine three recent regulation-validity decisions: Varian Medical Systems, Keysight Technologies, and Siemens Medical Solutions. These cases concern the Section 78 gross-up, GILTI deductions, extraordinary dispositions, and the Section 245A dividends-received deduction. The conversation also addresses judicial precedent, protective refund claims, return and financial-statement positions, possible government appeals, and the IRS’s potential use of economic substance and other alternative arguments when challenged regulations do not survive.
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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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