Cross-border Tax Talks

• One Big Beautiful Podcast, Part 5: Outbound Edition

  Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Wade Sutton, a principal who leads the international tax team in PwC’s Washington National Tax Services practice. Doug and Wade discuss OB-3’s outbound impacts and the ripple effects across the system: CAMT interactions and credit ordering; Section 174 R&E expensing elections; Section 163(j) excluding CFC items and the financing/on-lending response; FDII’s shift to FDDEI, a permanent 14% rate, and 2026 expense-apportionment relief; GILTI’s rebrand to Net CFC tested income with a 14% effective rate and ‘directly allocable’ expense questions; inventory-sourcing relief; repeal of the Section 898 one-month deferral; permanent CFC look-through; the Section 958(b)(4) fix; a new Section 951(a)(2)(B) framework; selected technical corrections; and why granular modeling matters now more than ever.  

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  35:47

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  35:47
• One Big Beautiful Podcast, Part 4: Inbound Edition

  Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Nita Asher, an international tax principal in PwC’s Washington National Tax Services practice focused on inbound multinationals, with prior government experience during the TCJA. Doug and Nita discuss the One Big Beautiful Bill Act (“OB3”) and its impact on inbounds, including permanent 100% bonus depreciation; new Section 168N for qualified production property; Section 163(j)’s EBITDA-based ATI; the reworked ‘FDDEI’ (formerly FDII) and its 14% rate with outbound IP limits; shifting IRA credit timelines and ‘foreign entity of concern’ issues; BEAT’s modest rate bump to 10.5% and unchanged credit treatment; the potential future of Section 899; and CAMT interactions. Throughout, they emphasize modeling to avoid BEAT/CAMT whipsaws while capturing OBBBA cash-flow benefits.

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  41:40

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  41:40
• Pillar Two Hybrid Arbitrage: stormy waters ahead?

  Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Raza Janjua, a Director in PwC’s ITS practice in New York and author of a recent article on Pillar Two hybrid arbitrage arrangements. Doug and Raza discuss the BEPS Action 2 origins and ATAD 2 implementation; how Pillar Two’s simplified safe harbors spawned detailed hybrid arbitrage rules; the core categories—deduction–non‑inclusion, duplicate loss, and duplicate tax recognition; real‑world traps like preferred equity treated as book debt, FX‑driven mismatches, valuation‑allowance hypotheticals, cash pools and back‑to‑backs; narrow dual‑inclusion relief and why it should be jurisdiction‑level; CFC‑regime interactions; retroactivity and early adoption; and what future administrative guidance and the G7 architecture could mean for US rules such as Sections 245A(e), 267A, and the DCL regime.  

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  43:05

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  43:05
• Geopolitics, Protectionism, and the Future of Global Commerce

  Doug McHoney (PwC’s International Tax Services Global Leader) is joined by returning guest Craig Stronberg, Senior Director of PwC Intelligence. Craig previously had a near 20-year career in National security affairs before joining PwC. Craig and Doug discuss changes to US global policy and protectionism; the rise of new global powers and alliances; the growing divide between developed and developing countries regarding global tax policy; the debate over globalization’s benefits; and the current trade environment. They also discuss how multinational companies are responding to uncertainty, deploying corporate risk management, scenario planning, and gaining competitive advantages. 

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  45:27

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  45:27
• Careers in tax: Two international tax titans

  Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Mike Urse and Calum Dewar, both retiring PwC International Tax partners with decades-long careers in cross-border tax. Mike served as PwC’s US ITS Leader, while Calum built his career across PwC UK and PwC US, specializing in European and global tax systems. Doug, Calum and Mike discuss the dynamic nature of international tax and the intellectual curiosity that drew them to the profession. They also reflect on the evolution of PwC’s international tax practice, consensus-driven leadership, and building high-performing teams. The trio shares stories on mentorship, the impact of technology - from dictaphones to AI - and how global tax reform has shaped the practice. With humor and candor, they offer career advice to current and future tax professionals and celebrate the relationships, challenges, and learning that have defined their time at PwC. 

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  36:22

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