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PwC specialists share insights and perspectives on key issues impacting the ever-changing international tax landscape. Our podcasts aim to provide quick, easy and up-to-date international 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.

Cross-border tax talks PwC

    • Wirtschaft

PwC specialists share insights and perspectives on key issues impacting the ever-changing international tax landscape. Our podcasts aim to provide quick, easy and up-to-date international 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.

    Global Tax Update: Around the world in 35 minutes

    Global Tax Update: Around the world in 35 minutes

    Doug McHoney (PwC's US International Tax Services Leader) and Pat Brown (PwC's International Tax Policy Leader) discuss the past, present, and future of US and global corporate taxation in 2020 and beyond. Doug and Pat discuss: issued and pending TCJA regulatory guidance, including anti-hybrid, Section 163(j), Foreign Derived Intangible Income (FDII), Global Intangible Low-Taxed Income (GILTI) high-tax exception, previously-taxed earning and profits (PTEP), and Foreign Tax Credit (FTC) regulations; Treasury's effort to have all TCJA guidance 'done' by October 2020, and what 'done' actually means; the interplay between OIRA, Treasury, and the White House; potential changes to the US corporate tax structure and rate after November's presidential election; the sustainability of the Section 250 deduction; the current state of the EU's Anti-Tax Avoidance Directive II (ATAD II); the global landscape of digital taxation; and continuing developments to the OECD's 'BEPS 2.0' initiative.

    • 37 Min.
    Merging lanes: key MA and international tax considerations after TCJA

    Merging lanes: key MA and international tax considerations after TCJA

    Doug McHoney (PwC's US International Tax Services Leader) and Mark Boyer (a Partner in PwC's Washington National Tax MA practice) discuss key MA and international tax considerations after the Tax Cuts and Jobs Act (TJCA). Doug and Mark discuss: life at the IRS before, during, and after the 1986 Tax Reform Act; top diligence concerns in MA transactions post-TCJA; how acquisitions unintentionally may subject companies to the Base Erosion and Anti-Abuse tax (BEAT); key structuring considerations post-TCJA, including the concept of a 'worldwide system of taxation' through BEAT, Foreign Derived Intangible Income (FDII), and global tax reform; the importance of modeling and data accuracy for tax and transaction planning; and the differences between strategic buyers and private equity.

    • 36 Min.
    Sourcing sorcery: New inbound taxation regs

    Sourcing sorcery: New inbound taxation regs

    Doug McHoney (PwC's US International Tax Services Leader) and Nils Cousin (International Tax Director in PwC's Washington National Tax Services practice) discuss the intricacies of income sourcing and the recently proposed Section 863(b) and 865 regulations. Among other topics they discuss: the background on sourcing rules and why these rules are so important; the general statutory framework for sales of personal property under Section 865; background on how Section 863(b) affects both 'inbound' and 'outbound' taxation; how the 2017 tax act amended Section 863(b)'s allocation rules; how treaties affect sourcing determinations; how the proposed regulations affect both US-based and foreign-based multinationals; and, finally, how and why taxpayers may elect to rely on the proposed regulations.

    • 35 Min.
    Brexit stage left: See EU later

    Brexit stage left: See EU later

    Doug McHoney (PwC's US International Tax Services Leader) and Matt Ryan (Leader of PwC UK's International Tax and Treasury Network) avoid the temptation of debating Megxit and dive quickly instead into Brexit. More specifically they cover: the importance of the monarchy to the UK's identity; a primer on the Brexit votes and the Prime Ministers in power during those votes; the treaty implications of Brexit; the importance of the ‘principal purpose test’; how Brexit will impact the new controlled foreign corporation (CFC), Permanent Establishment (PE), and dividends-received rules; how Brexit will impact global trade; and key considerations for companies in a post-Brexit world.

    • 33 Min.
    The New FTC Regs: Calculating tax in a galaxy far, far away

    The New FTC Regs: Calculating tax in a galaxy far, far away

    Doug McHoney (PwC's US International Tax Services Leader) and Tim Anson (International Tax Partner in PwC's Washington National Tax Services practice) discuss the recently issued final and proposed foreign tax credit (FTC) regulations. Doug and Tim discuss: the FTC's interplay with global intangible low-taxed income (GILTI); how 'branch IP' is treated in the final FTC regulations; how the final regulations treat expense allocation and apportionment at the CFC level; how the final regulations treat 'deemed paid' credits, including in foreign jurisdictions with different tax year-ends; how the final regulations interplay with Section 905(c) to create the potential for a multitude of amended returns; how the proposed FTC regulations treat research and experimentation apportionment; how the proposed regulations treat stewardship expenses; and how the proposed regulations provide specific rules for timing or base differences under Prop. Reg. sec. 1.861-20 (also known as 'dash 20.').

    • 42 Min.
    Tech Talk: How Leaders in Tax Embrace Technology

    Tech Talk: How Leaders in Tax Embrace Technology

    Doug McHoney (PwC's US International Tax Services Leader) and Roy Weathers (PwC's Vice Chair and US Tax Leader) 'co-develop' a podcast and discuss the dynamic nature of US and global tax reform, and how the tax practitioner's role continues to evolve during these transformative times. Doug and Roy cover: the role of technology and disruption in professional services organizations; how businesses can leverage 'citizen-led' approaches to technology; the infrastructure and budget required for 'enterprise-wide' technologies; the importance of scale in implementing technological tools; the challenges of encouraging and incentivizing adoption of various tools; how utilizing technology can free employees' time for added productivity and upskilling; the merging of law and technology, and the continued evolution of the soft and hard skills necessary for today's and tomorrow's practitioners.

    • 31 Min.

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