Cross-border Tax Talks

• When Purpose Meets Tax: How Teams Can Transform

  Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Leo Johnson, lecturer at Oxford University’s Smith School of Enterprise and the Environment. Leo is also co-founder of the advisory firm Sustainable Finance, where he chairs the Advisory Council, and previously worked at the World Bank. Known for presenting the BBC series on megatrends and innovation. Leo brings unique insight into organizational behavior, neuroscience, and purposeful leadership. Doug and Leo discuss organizational inertia, transformation resistance, and how neuroscience and behavioral science explain our resistance to change—even amid crises like climate change, geopolitical turmoil, and economic stress. They explore how professionals, including those in international tax, can overcome ‘learned helplessness’ and avoid burnout by embracing purpose, agency, and connectedness. Leo introduces the concept of behavioral personas within organizations—catalysts, silent rebels, workhorses, and sustaining innovators—and emphasizes the need for authentic engagement and collaboration to drive meaningful change. 

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• Itai Grinberg: The Pillar Two origin story (part 2)

  Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Professor Itai Grinberg, a faculty member at Georgetown University Law Center and a former Deputy Assistant Secretary at the US Treasury Department during the Biden administration. In that role, Itai served as the United States' lead negotiator for the global corporate minimum tax initiative. Doug and Itai discuss the behind-the-scenes history of Pillar Two from the US perspective, exploring its policy rationale, global negotiations, and shifting political dynamics. The conversation begins with how Itai’s got his role at Treasury and builds a detailed timeline tracing the Biden administration’s early support for global minimum tax rules through the 2021 G7 agreement and the development of the Under-Taxed Profits Rule (UTPR). They also delve into the impact of the Build Back Better legislation which was not enacted, the rationale behind the US safe harbor under UTPR, international political tensions including Brexit and US-China relations, and the implications of the April 2025 Trump executive order. The episode closes with reflections on the OECD Inclusive Framework’s future and whether multinational enterprises can expect a workable consensus moving forward. 

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• German Tax Update: Freshly served

  Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Arne Schnitger, a Berlin-based International Tax Partner at PwC Germany and co-host of the German-language tax podcast “Frisch Serviert.” Arne previously served in the German Ministry of Finance and brings deep insight into both domestic and cross-border policy developments. Doug and Arne discuss Germany’s evolving corporate tax landscape, including potential rate reductions, simplification initiatives, and the implications of recent coalition negotiations. They dive into Germany’s controlled foreign corporation (CFC) regime, explore the mechanics of the constitutional ‘German debt brake,’ and unpack recent developments surrounding Pillar Two. The conversation highlights the intersection of German and US tax policy, the ongoing tension between multilateralism and unilateral measures, and the administrative and technical challenges multinationals face under the global minimum tax framework. They also examine prospects for EU-level simplification and the future of long-standing anti-avoidance measures in light of Pillar Two implementation. 

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• Withholding retaliation? US Sections 891 and 899

  Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Tom Patten, a London-based US International Tax Partner at PwC. Tom focuses on inbound investment into the U.S. and returns to the podcast for a timely discussion on Sections 891 and 899, two lesser-known but increasingly important provisions in the international tax landscape.  Doug and Tom discuss the resurgence of Section 891 in light of a January 2025 executive order that directs Treasury to identify discriminatory or extraterritorial foreign taxes. They cover how Section 891 operates, potential implications for non-US citizens, and its interaction with treaties. The episode then turns to proposed Section 899 and a new House proposal aimed at modifying the base erosion and anti-abuse tax (BEAT). Tom and Doug examine how these retaliatory measures differ, overlap, and might evolve. They close with practical advice for multinational taxpayers navigating an uncertain legislative environment and the future of Pillar Two negotiations. 

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  40:57
• Brazil Tax Update: Full inclusion to full immersion

  Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Dr. Romero Tavares, PwC Brazil’s International Tax Leader and a professor of international tax law in São Paulo. Doug and Romero discuss the increasing intersection between Brazil’s international tax policy and global trade dynamics, including the effects of recent US executive orders. They cover Brazil’s high-tax corporate environment, its historically aggressive CFC-like full inclusion regime, and the country’s rapid adoption of a qualified domestic minimum top-up tax (QDMTT). The conversation explores the political and policy rationale behind these moves, the anticipated redesign of Brazil’s CFC regime, and the operational challenges multinationals face with the new OECD-aligned transfer pricing rules. Romero also breaks down Brazil’s massive indirect tax reform and the country’s potential shift to more internationally-aligned tax norms, while questioning the long-term viability of the undertaxed profits rule (UTPR) and Pillar Two’s durability under changing geopolitical winds. 

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