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Cross-border Tax Talks

September 20, 2021

Tax Reform 2.0:  the House "Ways" in

Doug McHoney (PwC's US International Tax Services Co-Leader) is live at the Westminster Studios with Sherry Grabow (PwC's US International Tax Services Co-Leader) to discuss the international tax provisions in the recently released ‘Chairman’s Mark’ from the House Ways and Means Committee. Doug and Sherry cover, among other topics: Interest expense under new Section 163(n) and existing Section 163(j); changes to foreign derived intangible income (FDII), modifications to the global intangible low-taxed income (GILTI) regime, changes to the foreign tax credit rules; sweeping changes to subpart F income; a refreshed base erosion and anti-abuse tax (BEAT), and how taxpayers should prepare for potential changes to the tax rules.


  • 4:00 - What are the changes to interest expense, specifically under new Section 163(n) which limits interest deduction of certain domestic corporations and foreign corporations that are engaged in a US trade or business and are members of an international financial reporting group?

  • 8:30 - What changes were made to the existing foreign derived intangible income provision?

  • 12:30 - What is the proposed new GILTI rate and overall changes to the calculation?

  • 21:45 - What are some of the changes to the foreign tax credit, including the new carryforward and removal of the branch basket? 

  • 29:15 - What are some of the surprising changes to the subpart F rules that have been around since 1962?

  • 32:30 - What are the proposed changes to BEAT?  

  • 36:00 - What are some of the other international provisions contained in the House Ways & Means bill?

  • 39:30 - How should taxpayers prepare for these expected changes as we get closer to final legislation?

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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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