Cross-border Tax Talks

Still tariffied: Refunds, reshoring and risk

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Chris Desmond, leader of PwC US’s Global Trade Services practice and, as Doug puts it, a 'reformed Transfer Pricing Partner.' Doug and Chris, recording at PwC’s 2026 Global Transfer Pricing, Trade, and Indirect Taxes Conference in Chicago, discuss the progress of IEEPA tariff refunds and the related accounting, legal-entity, and transfer pricing decisions; continuing US tariff authority and trade tensions involving China, the European Union, Canada, and Mexico; and selective supply-chain reshoring. They also examine pharmaceutical tariff developments, White House deals, customs valuation and reconciliation, first-sale planning, and heightened audit exposure. The conversation closes with AI’s potential and limitations in trade compliance and three priorities for tax leaders: aligning customs and tax data, coordinating transfer pricing adjustments, and scenario planning. 

• [01:10] – Cubs versus Cardinals: How did their 2026 baseball seasons unfold?
• [03:15] – What has changed in the tariff landscape since the Supreme Court's IEEPA ruling? What is the status of IEEPA tariff refunds?
• [05:20] – What tax and transfer pricing implications arise from receiving tariff refunds?
• [06:30] – How should companies evaluate the timing, legal-entity allocation, and audit implications of refunds? Doing nothing is not an option.
• [08:15] – What is the current US tariff framework following the IEEPA ruling, including Sections 232 and 301?
• [11:00] – How is China responding to US tariffs, and what does the latest trade truce mean?
• [12:05] – How is the EU balancing negotiated trade concessions with potential retaliatory measures? What about Canada and USMCA negotiations?
• [13:45] – How is Mexico approaching trade negotiations and US automotive content requirements?
• [14:45] – Could other US tariff authorities face successful legal challenges?
• [15:50] – How are multinational companies selectively de-risking and reshoring their supply chains, particularly pharmaceutical and technology companies?
• [18:00] – What are the tax and transfer pricing consequences of changing supply-chain functions, risks, and intangibles?
• [19:00] – How are tariffs and customs reconciliations changing the relationship between transfer pricing, customs valuation, and tax structuring?
• [22:50] – What do the announced 2028 and 2029 tariffs mean for generic pharmaceutical manufacturers?
• [24:55] – Why are customs audit recoveries increasing, and what enforcement risks should companies prioritize?
• [26:14] – How do country-of-origin determinations and product classifications create customs audit exposure? What valuation risks arise from royalties, management fees, and customs assists?
• [27:55] – How does first-sale valuation reduce tariffs, and what are the associated compliance and audit risks?
• [29:15] – How can AI improve customs data analysis, compliance monitoring, and tariff planning? What are the risks of relying on AI-generated analyses?
• [32:40] – What three actions should global tax leaders prioritize over the next 90 days?
  • Priority one: Reconcile customs data with tax, ERP, and transfer pricing information.
  • Priority two: Include customs teams in transfer pricing adjustment decisions.
  • Priority three: Conduct scenario planning for potential changes to USMCA and global tariff policies.
• [34:30] – Will Major League Baseball see a collective bargaining agreement?

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