Cross-border Tax Talks

• After-Tax KPIs: A SVP of Tax’s perspective

  Doug McHoney (PwC’s International Tax Services Global Leader) is joined by returning guest Tadd Fowler, Senior Vice President, Treasurer, and Global Taxes at the Procter & Gamble company. Doug and Tadd discuss US tax policy after the Tax Cuts and Jobs Act, the OB3 package’s priorities and fixes (including interest expense apportionment, GILTI and FDII changes, and maintaining competitiveness), and why certainty still depends on ongoing policymaker education. They examine the OECD Pillar Two ‘side‑by‑side’ concept, the daunting Pillar Two compliance overlay on US rules, and P&G’s own Pillar Two posture. They also cover operating‑model design, incentives and foreign direct investment, how AI augments rather than replaces decisions, and the tax team’s priorities—business partnership, compliance productivity, people and capabilities, and advancing tax certainty through transparency and cooperative programs.  

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  44:33

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  44:33
• Pillar Two: UK realities

  Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Matt Ryan, PwC UK’s International Tax and Treasury Network Leader and the UK’s Pillar Two lead. Recording in Barcelona at PwC’s Global Tax Symposium, they take stock of Pillar Two implementation and the much‑watched ‘side‑by‑side’ agreement. Doug and Matt discuss policymakers’ evolving openness to net CFC tested income (NCTI) coexistence, the UK’s 2027 legislative path with potential effect from 2026, the UTPR safe harbor expiration, practical frictions around POPE reporting, M&A data gaps, and the lack of a global dispute mechanism. They also examine transitional versus permanent safe harbors, potential consequences if Section 899 re‑emerges—including expanded BEAT exposure—and quick UK updates on the 25% corporate rate and the digital services tax.  

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  30:28
• OB3 Curveballs: Federal Tax interplay and State Tax conformity

  Wade Sutton (PwC’s WNTS International Tax Services Leader) guest hosts the podcast and is joined by Rob Ozmun, a State and Local Tax Partner, and Monic Kechik, PwC’s WNTS Federal Tax Services Leader. Together they discuss the OB3 ‘curveballs’ to the federal changes: Section 163(j) - ATI addbacks of depreciation and amortization; Section 174A - domestic expensing; Section 168(k) - the return to 100% bonus depreciation; and Section 168(n) - qualified production property (QPP). They explore how accelerated deductions can trigger BEAT and CAMT via ordering‑rule dynamics and book‑tax timing, creating cash‑vs‑ETR trade‑offs that can be addressed with capitalization provisions. They also examine state conformity models, rapid decoupling (e.g., D.C.), and wrinkles such as California’s departures and R&D credits.

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  33:15

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• Beyond Pillar Two: Global tax policy update

  Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Will Morris, PwC’s Global Tax Policy Leader, from PwC’s Global Transfer Pricing, Customs, and Indirect Tax Conference in Prague. Doug and Will discuss how trade policy now shapes tax outcomes, the G7 ‘side‑by‑side’ debate for Pillar Two, and why geopolitics complicates an Inclusive Framework deal. They explore the EU’s ‘simplification’ agenda (FTT/DEBRA/Unshell pullbacks), overlapping anti‑abuse regimes post-Pillar Two, and whether real simplification is politically feasible. The conversation turns to Digital Services Taxes amid Pillar One uncertainty, potential US responses (including Section 301 and talk of Section 899), and the rise of Significant Economic Presence rules. They close with the UN’s emerging convention, source‑based taxation of services, and the limits of AI and automation when dealing with unstructured taxpayer data.  

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  37:52

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  37:52
• Tariff Tug-of-War: Coordinating your trade strategy

  Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Chris Desmond, a Principal in PwC’s Customs & Trade Practice. Chris leads PwC US’s Global Trade Services. Doug and Chris, while at PwC’s Global Transfer Pricing, Customs, and Indirect Tax Conference in Prague, discuss the Supreme Court’s expedited review of IEEPA‑based tariffs, possible outcomes, and the implications of an estimated ~$108B refund exposure across multiple industries (See our PwC Insight: IEEPA Tarrif: Understanding the Potential outcomes ahead of the Supreme Court’s Ruling for more details). They cover how persistent tariffs elevate customs to the C‑suite and require close integration with transfer pricing and Pillar Two modeling. They also discuss practical mitigations including first sale for export, duty drawback, Harmonized Tariff Schedule (HTS) reclassification and origin analysis, transfer‑pricing alignment, and use of foreign‑trade zones -- paired with rigorous controls as US government scrutiny intensifies. The episode closes with sector‑specific developments and a data‑driven playbook.  

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