Cross-border Tax Talks

US Tax Policy: What’s Staying, What’s Going, and What’s Next?

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Pat Brown, an International Tax Partner and Co-Leader of PwC’s Washington National Tax Services practice. Together, they unpack the state of US corporate tax policy in 2025, analyzing how regulatory, legislative, and geopolitical forces could shape the next era of taxation. Doug and Pat dissect the final regulations issued in the closing days of the Biden administration, including the controversial disregarded payment loss (DPL) regulations, finalized and proposed digital content and cloud sourcing rules, and updates on corporate basis-shifting transactions. With a new administration in power, they explore whether these rules will stand, be modified, or be repealed entirely—and what this means for business certainty and planning. The conversation then pivots to legislative challenges, as the expiration of key provisions from the 2017 Tax Cuts and Jobs Act (TCJA) creates a ticking time bomb for tax policy.  Finally, they tackle the international tax front, where the US f administration responds to the OECD’s Pillar Two and potential digital services tax (DST) retaliation under new proposals like Section 899.  

Timestamps:

• 00:00 – Doug welcomes back Pat Brown to discuss the evolving US tax landscape. 
• 4:10 – Regulatory Blitz: A review of the last-minute Treasury regulations issued before Biden left office, starting with the Disregarded Payment Loss (DPL) and Dual Consolidated Loss (DCL) Rules. What is the future of these regulations? 
• 9:30 – Cloud Tax Rules & Digital Content: A summary and the long-term implications of the regulations on cloud transactions and digital content. 
• 12:30 - How have other administrations dealt with regulations published before a change in administration?  How might the new administration address these regulations? 
• 15:00 – Might Congress invoke the Congressional Review Act for any of these regulations? 
• 16:00 – Tax Cuts and Jobs Act 2.0 - why is 2025 such a big year for the original TCJA? 
• 18:50 – TCJA Expiration: Which corporate tax provisions will sunset, and what happens if Congress does nothing? 
• 20:25 – Can tariffs and other factors outside of a traditional tax bill be part of the reconciliation math? 
• 23:35 – One bill versus two bills in reconciliation. Why does tax reform depend on political dealmaking? 
• 28:25 – What corporate tax provisions could Congress change and what are the Republican tax priorities? 
• 33:55 – Is Jurisdictional GILTI on the table? 
• 36:10 – What about the BEAT? Is it working as intended? 
• 39:00 – What is the fate of the corporate alternative minimum tax (CAMT)? 
• 40:15 – Could we see action on either Section 891 or Proposed Section 899? How might they impact treaty obligations? How would it impact Pillar Two? 

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