Cross-border Tax Talks

Doug McHoney, PwC’s International Tax Services Global Leader, is joined by Mario Alberto Gutierez, International Tax Partner based in Mexico City, and Leader of PwC’s International Tax Practice in Mexico. Doug and Mario discuss Mexico’s implementation of the multilateral instrument, Mexican tax treaties and the potential for treaty abuse, how the 2022 Tax Act changes the game with regard to share transfers, the Maquiladora regime, the Mexican manufacturing industry more broadly including business transformations and ‘near shoring,’ and debt structures and the ‘inflation adjustment’ in Mexico. Not surprisingly, Pillar Two makes a cameo appearance.

Doug McHoney, PwC’s International Tax Services Global Leader, is in Barcelona, Spain at PwC’s Global Tax Symposium. On this episode, Doug is joined by Matt Ryan, a UK-based International Tax Partner with PwC. Doug and Matt discuss the UK’s parliamentary process, Liz Truss’s resignation, the corporate tax proposed changes, and Pillar Two, including a qualified domestic minimum tax, the income inclusion rule, and the under taxed payments rule. They also cover the finer points of UK’s treatment of asset transfers, deferred taxes, year-end adjustments, and the system and data requirements that companies must address.

Doug McHoney, PwC’s International Tax Services Global Leader, is at PwC’s Global Transfer Pricing Conference in Berlin, Germany, joined by Omri Yaniv, Global Head of Tax at Amdocs Ltd, based in Tel Aviv. Omri is a former PwC partner, and the first Tax VP from a non-US-parented company to appear on the podcast. Doug and Omri discuss the three pillars of Omri’s job, Amdocs’ tax department, the accounting talent war, recent global tax changes, and the potential changes on the horizon.

Doug McHoney, PwC’s International Tax Services Global Leader, welcomes Horacio Pena, Tax Principal, Senior Economist and PwC’s Global Transfer Pricing Network Leader, to the podcast. Doug and Horacio provide the macroview of the transfer pricing environment, covering global inflation, China’s COVID restrictions, environmental volatility, the dollar’s strengthening against other currencies, regionalization, a brief touch on Pillar Two, country-by-country reporting, and more.

Doug McHoney, PwC’s Global International Tax Services Leader, is at PwC’s Global Transfer Pricing Conference in Berlin, Germany. Doug honors Ocktoberfest by donning lederhosenis to host Arne Schnitger, PwC International Tax Partner based in Berlin. Arne hosts the German tax podcast Frisch Serviert - der Steuerpodcast. They discuss Pillar Two issues in the EU, the US, and Germany, the differences approaches each jurisdiction takes when calculating the tax, the US book minimum tax, GILTI, refundable credits, allocation of expenses, the German implementation process, tax return filing, operational readiness, German anti-hybrid rules, and German Section 49.

Doug McHoney (PwC's Global International Tax Services Leader) welcomes Rebecca Lee (Washington National Tax Services International Tax Partner). Doug and Rebecca discuss the many tax aspects of a strong US dollar, including cream skimming, foreign exchange gains and losses with branches and CFCs, previously taxed earnings, translational versus transactional gain or loss, and more. Can Doug and Rebecca go the entire podcast without mentioning a code section? Tune in to find out!

Doug McHoney (PwC's Global International Tax Services Leader) welcomes first-time guest Kristina Novak (Washington National Tax Services Transfer Pricing Principal) and returning guest Alex Voloshko (PwC’s Value Chain Transformation Leader) to discuss the Medtronic case. They highlight the key takeaways including intellectual property considerations, transfer pricing trends, licensing models, business transformation trends for customers, and of course, a brief discussion of how Pillar Two will fit in.

Doug McHoney (PwC's Global International Tax Services Leader) welcomes Rebecca Lee, International Tax Services Principal in the Washington National Tax Practice for her sixth visit. Doug and Rebecca dispel myths associated with cryptocurrency and the metaverse. They break down definitions of some of the trickiest metaverse jargon, the tax implications of metaverse transactions, and where we are heading in the near future.

Doug McHoney (PwC's Global International Tax Services Leader) welcomes back podcast regular Calum Dewar (Principal, International tax services) to discuss Pillar Two. This time Doug and Calum dive deep into the deals area, including the Pillar Two tax consequences of specific deal transactions and structures. They also talk about the recent release of both the South Korea and UK Pillar Two draft rules.

Doug McHoney (PwC's Global International Tax Services Leader) is joined by Aaron Junge in Westminster Studios. Aaron is International Tax Partner in PwC’s Washington’s National Tax Services and was previously Tax Counsel in the House Ways and Means Committee during the Tax Cuts and Jobs Act implementation. Doug and Aaron discuss the corporate alternative minimum tax (also called the ‘Book Minimum Tax’) and other Inflation Reduction Act tax provisions, which President Biden signed into law on August 16. More specifically, they cover the BMT effective date and its scope, what are applicable corporations, changes to the aggregation rules, what is applicable financial statement income, common adjustments, calculating the AMT foreign tax credit, and what guidance we might see from Treasury.