PwC specialists share insights and perspectives on key issues impacting the ever-changing tax landscape. Our podcasts aim to provide quick, easy and up-to-date tax developments to help you stay current and competitive in today's challenging business environment. Listen to episodes at your convenience via your desktop computer or smart device.
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The EY Cross-Border Taxation Podcast series brings you a weekly review of the latest US international tax-related developments.
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As the world turns: Macroeconomic trends
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Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s International Tax Conference in Dana Point, California with Dr. Alexis Crow, PwC’s Geopolitical Investing Practice Leader. Doug and Alexis discuss the recession outlook and economic activity, the impact of inflation, central banking policy, including interest rates, commercia…
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EY Cross-Border Taxation Spotlight for Week ending 26 April 2024
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A review of the week's major US international tax-related news. In this edition: US tax policy lines being drawn ahead of 2024 election, TCJA ‘cliff’ – IRS finalizes domestically controlled qualified investment entity rules under FIRPTA – IRS publishes draft digital asset Form 1099-DA – US says draft Australian ruling on cross-border computer softw…
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EY Cross-Border Taxation Spotlight for Week ending 19 April 2024
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A review of the week's major US international tax-related news. In this edition: IRS waives penalty for failure to pay estimated CAMT – OECD BEPS 2.0 update: what’s coming – IESBA announces changes to its Tax Planning and Related Services project that will apply to all tax planning activities.Por EY
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EY Cross-Border Taxation Spotlight for Week ending 12 April 2024
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A review of the week's major US international tax-related news. In this edition: IRS releases proposed stock buyback excise tax regulations – US Treasury official discusses BEPS 2.0 Pillar Two negotiations – Congressional Joint Committee on Taxation reviewing global developments in updating BEPS Pillar Two analysis – OECD official says Pillar One M…
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EY Cross-Border Taxation Spotlight for Week ending 5 April 2024
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A review of the week's major US international tax-related news. In this edition: US Congress returns from spring recess; no movement on tax bill – IRS releases latest APA report – OECD misses deadline on BEPS Pillar One MLC on Amount A.Por EY
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EY Cross-Border Taxation Spotlight for Week ending 29 March 2024
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A review of the week's major US international tax-related news. In this edition: US Treasury Secretary affirms commitment to BEPS Pillar One, US R&D in Pillar Two – US government officials offer international regulatory update.Por EY
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Doug McHoney (PwC’s International Tax Services Global Leader) is in São Paulo, Brazil for the first Latin American recording of the CBTT with PwC Brazil’s International Tax Leader Dr. Romero Tavares. Doug and Romero discuss what makes Brazil’s tax system so unique – from its transfer pricing rules to its full inclusion regime. They also dive into e…
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EY Cross-Border Taxation Spotlight for Week ending 22 March 2024
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A review of the week's major US international tax-related news. In this edition: Congress, Biden Administration reach agreement on budget deal; tax bill in limbo – IRS stock buyback regs weeks away, CAMT project further delayed – Mandatory binding arbitration remains US tax treaty policy – US working to protect R&D benefits under BEPS Pillar Two.…
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EY Cross-Border Taxation Spotlight for Week ending 15 March 2024
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A review of the week's major US international tax-related news. In this edition: President Biden releases proposed FY 2025 Budget – IRS issues final revised Form W-9 with new requirement to identify direct or indirect foreign partners – US announces agreement with Türkiye to extend moratorium on unilateral measures, including DSTs.…
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Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s International Tax Conference in Dana Point, California with former House Ways & Means Chairman Dave Camp, now senior policy advisor in PwC’s Washington National Tax Services. Doug and Chairman Camp discuss his political career, drivers behind US tax policy, how Congress negot…
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EY Cross-Border Taxation Spotlight for Week ending 8 March 2024
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A review of the week's major US international tax-related news. In this edition: President Biden delivers State of the Union address, offers new tax proposals – US House Ways & Means Tax Subcommittee holds hearing on OECD BEPS Pillar 1 – OECD Secretary-General Tax Report offers insights on BEPS project.…
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EY Cross-Border Taxation Spotlight for Week ending 1 March 2024
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A review of the week's major US international tax-related news. In this edition: US IRS exempts Form 1042 electronic filing in 2024 for US and nonresident withholding agents – IRS will no longer issue significant single issue PLRs – US Senate approves nomination of new IRS Chief Counsel – EY launches new tax podcast series.…
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Geopolitics Unraveled: Trends for 2024
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In this episode of Cross-Border Tax Talks, Doug McHoney interviews Craig Stronberg, a Senior Director in PwC's Intelligence Team, about major geopolitical trends impacting business leaders and the operating environment. They discuss topics such as protectionism, the US-China rivalry, distrust, the shift in global power, tech disruption, labor, and …
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EY Cross-Border Taxation Spotlight for Week ending 23 February 2024
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A review of the week's major US international tax-related news. In this edition: US Congress to return to session – OECD releases final guidance on BEPS Pillar One Amount B on baseline distributions.Por EY
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EY Cross-Border Taxation Spotlight for Week ending 16 February 2024
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A review of the week's major US international tax-related news. In this edition: US House and Senate recess; focus to turn to approaching government funding deadlines, tax package possible – IRS sending info request letters to US-based subsidiaries of foreign-owned corporations re intercompany transaction pricing – IRS plans to finalize proposed FX…
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US Guidance Update: Pillar Two and more
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On this episode, Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Wade Sutton. Wade is PwC’s Washington National Tax Service’s ITS Leader, a former adjunct professor of international tax at Georgetown University's Law Center, and former Deputy International Tax Counsel, US Treasury. Doug and Wade discuss what drove them to…
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EY Cross-Border Taxation Spotlight for Week ending 9 February 2024
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A review of the week's major US international tax-related news. In this edition: US House-passed tax package may require Senate Finance Committee markup – Senate begins two-week recess.Por EY
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Sustainability and Transparency for Tax Professionals
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In this podcast episode, Doug McHoney, PwC’s International Tax Services Global Leader, interviews Heather Horn, PwC's Assurance National Thought Leader and host of the twice-weekly PwC Accounting Podcast. Doug and Heather discuss sustainability reporting and its increasing importance in the business world. They cover various regulations and standar…
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EY Cross-Border Taxation Spotlight for Week ending 2 February 2024
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A review of the week's major US international tax-related news. In this edition: US House of Representatives passes tax package; Senate action unclear – IRS expects to finalize two sets of Section 367 proposed regulations in first half of 2024 – Senate Finance Committee again approves IRS Chief Counsel nomination – OECD releases first statistics on…
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EY Cross-Border Taxation Spotlight for Week ending 26 January 2024
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A review of the week's major US international tax-related news. In this edition: US tax package may get House floor vote week of 29 January, future in the Senate uncertain – US officials offer international tax regulatory update on CAMT, stock buyback excise tax, cloud computing and PTEP rules – OECD releases working paper on global minimum tax and…
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Pillar Two: how safe is the safe harbor?
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Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Steve Kohart for our first podcast in PwC’s New York studio. Steve is a PwC international tax partner based in New York, and a former adviser for the OECD Center for Tax Policy and Administration. Doug and Steve discuss the OECD’s latest Pillar Two Administrative Guidance, w…
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EY Cross-Border Taxation Spotlight for Week ending 19 January 2024
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A review of the week's major US international tax-related news. In this edition: House and Senate tax writers release $78 billion tax package – Congress passes CR to fund the government – IRS announces cryptocurrency transactions do not have to be reported until regulations issued.Por EY
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EY Cross-Border Taxation Spotlight for Week ending 12 January 2024
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A review of the week's major US international tax-related news. In this edition: US Congress returns from recess, government spending and possible tax package on the agenda – IRS to release CAMT package shortly – Treasury official offers US position on BEPS Pillar One – OECD Working Paper addresses global minimum tax and MNE taxation – EY releases …
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EY Cross-Border Taxation Spotlight for Week ending 5 January 2024
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A review of the week's major US international tax-related news. In this edition: US-Hungary tax treaty ceased to have effect – IRS issues interim guidance on basis adjustments re: inbound liquidations or asset reorganizations – IRS updates list of treaty partner countries – IRS broadens scope of possible private letter rulings.…
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Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s Tax Leadership Conference in breezy Orlando with Dom Megna, a New York-based tax partner leading PWC's US Tax Reporting and Strategy Practice. Doug and Dom discuss Artificial Intelligence (AI) and its place in tax. They focus on four areas - what is conversational AI, machine…
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EY Cross-Border Taxation Spotlight for Week ending 22 December 2023
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A review of the week's major US international tax-related news. In this edition: OECD/G20 Inclusive Framework releases BEPS 2.0 Pillar Two Administrative Guidance on GloBE rules – OECD announces new BEPS Pillar One MLC timeline – US-Chile income tax treaty enters into force – US Congress adjourns until January 2024 – Congressional JCT releases Blue…
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Taxing FX of Branches: the new Section 987 regulations
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Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Rebecca Lee (WNTS ITS Partner) in PwC’s Washington, DC studio for the 140th (and Rebecca’s) episode of the Cross-Border Tax Talks podcast. Rebecca, a frequent guest on the podcast, specializes in financial transactions and digital assets. Doug and Rebecca discuss the history…
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EY Cross-Border Taxation Spotlight for Week ending 15 December 2023
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A review of the week's major US international tax-related news. In this edition: US Treasury and IRS issue FTC guidance addressing BEPS 2.0 Pillar Two GloBE top-up taxes – IRS CAMT regs delayed to 2024, but CAMT Notice released – IRS announces active compliance campaign on CAMT – Stock buyback excise tax guidance still on track for 2023 release – I…
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UK Pillar Two: Painting while the paint dries
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Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Matt Ryan at PwC’s Global Tax Symposium in Rome. Matt is a London-based international tax partner and PwC UK’s Pillar Two Leader. Doug and Matt revisit the UK Pillar Two rules for the third time, but now from an enacted law perspective. While the rules are set to apply from …
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EY Cross-Border Taxation Spotlight for Week ending 8 December 2023
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A review of the week's major US international tax-related news. In this edition: US Supreme Court holds oral arguments in Moore transition tax case – Congress set to adjourn next week.Por EY
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Pillar Two: Policy, politics and interaction with Pillar One
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Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s Global Tax Symposium in Rome, where he’s joined by Will Morris. Will is PwC’s Global Tax Policy Leader, and on Will’s last visit to the podcast, he covered FSR, the Foreign Subsidies Regulation. On this podcast, an exciting and familiar topic - Pillar Two! Doug and Will discu…
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EY Cross-Border Taxation Spotlight for Week ending 1 December 2023
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A review of the week's major US international tax-related news. In this edition: US-Taiwan tax bill moves forward – OECD to release additional BEPS 2.0 Pillar Two guidance by year-end.Por EY
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Pillar One: Policy, politics and interaction with Pillar Two
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Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s Global Transfer Pricing Conference where he’s joined by Giorgia Maffini. Giorgia is part of PwC’s Global Transfer Pricing team in London and was previously the Deputy Head of the Tax Policy and Statistics Division at the OECD. Doug and Giorgia discuss why taxpayers should car…
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EY Cross-Border Taxation Spotlight for Week ending 22 November 2023
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A review of the week's major US international tax-related news. In this edition: Prospects for US tax legislation uncertain – Canada confirms plans for Digital Services Tax, may lead to US response.Por EY
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EY Cross-Border Taxation Spotlight for Week ending 17 November 2023
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A review of the week's major US international tax-related news. In this edition: US Congress passes CR to fund government past 17 November deadline – Government officials offer update on CAMT, stock buyback excise tax and PTEP regs – Chilean Congress approves US-Chile tax treaty with US reservations – US proposing new deadline for signing BEPS 2.0 …
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Pillar Two Safe Harbors: The CbCR journey
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Doug McHoney (PwC’s International Tax Services Global Leader) is joined by David Ernick, a Principal with PwC’s Washington National Tax Services Transfer Pricing Practice and former Associate International Tax Counsel at the US Treasury Department, at PwC’s Global Transfer Pricing Conference in San Diego, California. They discuss Country-by-country…
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EY Cross-Border Taxation Spotlight for Week ending 10 November 2023
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A review of the week's major US international tax-related news. In this edition: US Treasury and IRS release proposed regulations on Section 987, income and currency gain or loss with respect to QBUs – US court denies Section 245A DRD deduction based on economic substance – Hungary authorizes signing of new US-Hungary CCA for exchange of CbC report…
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EY Cross-Border Taxation Spotlight for Week ending 3 November 2023
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A review of the week's major US international tax-related news. In this edition: IRS officials provide update on FTC guidance – US Treasury official comments on BEPS 2.0 project – US engaging with Canada on proposed DST – Senate Finance Committee approves new IRS Chief Counsel.Por EY
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On notice: US developments and Moore hype
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Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s Tax Leadership Conference in breezy Orlando with Pat Brown, frequent pod guest and co-leader of PwC’s Washington National Tax Services. They discuss US tax updates, including the status and fate of the Tax Cuts and Jobs Act (TCJA); the future of Section 163(j); notices and gu…
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EY Cross-Border Taxation Spotlight for Week ending 27 October 2023
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A review of the week's major US international tax-related news. In this edition: US House of Representatives chooses new speaker – US-Chile tax treaty’s reservations incorporated in US Model Treaty – US, Uruguay sign TIEA – IRS sending compliance alerts to 150 US-based subsidiaries of foreign-owned corporations – IRS says PTEP proposed regs now exp…
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EY Cross-Border Taxation Spotlight for Week ending 20 October 2023
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A review of the week's major US international tax-related news. In this edition: US will not sign MLC on BEPS Pillar One Amount A in 2023, further negotiations required – Treasury, IRS officials offer international tax guidance update, including FTCs, CAMT – IRS to expand PLRs to majority of subchapter C transactions – US House and Senate introduce…
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EY Cross-Border Taxation Spotlight for Week ending 13 October 2023
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A review of the week's major US international tax-related news. In this edition: OECD/G20 IF releases Multilateral Convention to Implement Amount A of Pillar One – US Treasury requests comments on Amount A Pillar One MLC – Senate Finance Committee leaders urge USTR to warn Canada of consequences of enacting DST.…
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EY Cross-Border Taxation Spotlight for Week ending 6 October 2023
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A review of the week's major US international tax-related news. In this edition: Continuing resolution funds US government through 17 November, House Speaker ousted – IRS issues proposed cross-border triangular reorganization regulations – US, Israel sign CA agreement to share CbC reports – OECD/G20 Inclusive Framework adopts Multilateral Conventio…
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Trick or treat(y): An update on US treaties
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Doug McHoney (PwC’s International Tax Services Global Leader) is back in Westminster Studios in St. Louis, Missouri with Nils Cousin, a Washington, D.C. based International Tax Services Principal specializing in US inbound taxation. Together they discuss tax treaties, mutual agreement procedures, the concept of competent authority, the treaty proce…
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EY Cross-Border Taxation Spotlight for Week ending 29 September 2023
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A review of the week's major US international tax-related news. In this edition: US Congress seeks consensus on continuing resolution to fund government past FY deadline – Senate Finance Committee holds hearing on IRS Chief Counsel nomination – House Ways and Means Committee members warn against Canada’s DST proposal.…
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EY Cross-Border Taxation Spotlight for Week ending 22 September 2023
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A review of the week's major US international tax-related news. In this edition: US House budget negotiations continuing – House Republican tax writers want countries to delay BEPS Pillar Two implementation, urge rules similar to US GILIT regime – US Senate Finance Committee hearing to consider new IRS Chief Counsel – US tax treaty negotiations wit…
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Moore v. US: Constitutionality of international tax
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Doug McHoney (PwC's International Tax Services Global Leader) and Wade Sutton (former Deputy International Tax Counsel for the US Treasury and newly appointed ITS leader of PwC’s Washington National Tax Practice) are back in Washington, D.C. to discuss the recent Supreme Court grant of certiorari for the Moore v. US case. Doug and Wade go back to t…
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EY Cross-Border Taxation Spotlight for Week ending 15 September 2023
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A review of the week's major US international tax-related news. In this edition: Senate Finance Committee approves Taiwan tax bill – IRS issues further interim CAMT guidance – IRS considering extending temporary foreign tax credit relief, BEPS Pillar Two-related FTC guidance in the works – IRS official offers preview of coming international tax gui…
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EY Cross-Border Taxation Spotlight for Week ending 8 September 2023
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A review of the week's major US international tax-related news. In this edition: US House Ways and Means Committee delegation meets with OECD officials on BEPS 2.0 – IRS opens CAP program for 2024 tax year – IRS announces major new compliance initiative focused on large partnerships, corporations, high-income taxpayers and “promoters abusing tax ru…
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Poutine Routine: Canada’s Pillar Two, DSTs, with G(AA)Ravy on top
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Doug McHoney (PwC's International Tax Services Global Leader) and Ken Buttenham meet up in PwC’s Washington, D.C.. studio. Ken leads PwC Canada’s International Tax Practice from Toronto. Doug and Ken kick off with a discussion on Doug’s favorite Canadian food, then dive into the Canadian Pillar Two proposals, discussing the Global Minimum Tax Act (…
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