에피소드 41개

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

    • 비즈니스

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.

    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.').

    • 42분
    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.

    • 31분
    We got the BEAT: US Tax Reform Regulations

    We got the BEAT: US Tax Reform Regulations

    Doug McHoney (PwC's US International Tax Services Leader) and Nita Asher (an International Tax Partner in PwC's Washington National Tax Services practice) discuss the background to, and recent guidance for the Base Erosion and Anti-abuse Tax (BEAT). Doug and Nita discuss Nita's work at the Joint Committee of Taxation during the formation and passage of the Tax Cuts and Jobs Act; the history and reasoning behind the BEAT; how the BEAT compares with the previously-proposed 'Border-Adjustment Tax,' or 'BAT'; how the recently-released final BEAT regulations treat GILTI, subpart F, and PFIC inclusions; how the recent final regulations treat 'netting'; how the recently proposed BEAT regulations permit taxpayers to voluntarily forego deductions and how they can retroactively apply this election; how the onshoring of intellectual property (IP) may affect taxpayers's BEAT computations; and how taxpayers may use distributions or other structuring decisions to mitigate BEAT implications from onshoring IP.

    • 33분
    BEPS 2.0: It's easy as (Amounts) A, B, C

    BEPS 2.0: It's easy as (Amounts) A, B, C

    Doug McHoney (PwC's US International Tax Services Leader) and Will Morris (PwC's Deputy Global Tax Policy Leader) pass an interesting smell test on the way to discussing the 'Digitalization of the Economy Project,' which Will reluctantly allows us to refer to as 'BEPS 2.0.' In this episode Doug and Will cover: an overview of the OECD's 'Unified Approach' under Pillar One and how various countries feel about this proposal; the historical context of the OECD's 'inclusive framework'; the reasoning behind the 'significant economic presence' concept and 'fractional apportionment' method; the potential difficulties in reaching a consensus among the 135 signatories to the 'Unified Approach' by late 2020; an overview of the three-tier profit allocation mechanism ('Amount A,' 'Amount B,' and 'Amount C'); the difficulties in determining what a 'consumer facing' and/or 'highly digitalised' business' is under Pillar One; the similarities between US tax reform (specifically BEAT and GILTI) and the OECD's proposals; and the challenges in addressing double-taxation issues under the OECD's proposals. They wrap with some prognosticating of 'Digitalization of the Economy Project,' (BEPS 2.0).

    • 43분
    Reforma en México: A tax reform discussion

    Reforma en México: A tax reform discussion

    Doug McHoney (PwC's US International Tax Services Leader) and Lissett Tautfest (PwC's International Tax Services Leader in Mexico) discuss a multitude of topics related to Mexican tax reform. Specific points of conversation include: the legislative process in Mexico; the timing and ratification process of the recent tax reform legislation; the relationship between Mexico and the OECD; the current corporate and withholding tax rates in Mexico; how interest deductibility will be computed after Mexican tax reform; notable exceptions to the interest deductibility rule; important questions businesses should consider pertaining to interest deductibility; when regulations may be issued related to non-deductible payments; how Mexican tax reform will affect foreign transparent vehicles; how Mexican tax reform will affect foreign service providers; and how Mexico has codified 'business purpose.'

    • 36분
    Properly attributing: a conversation on tax attribution after the TCJA

    Properly attributing: a conversation on tax attribution after the TCJA

    Doug McHoney (PwC's US International Tax Services Leader) and Aaron Junge (Tax Director in PwC's Washington National Tax Services office) go deep into attribution and determining ownership, focusing on Section 958(b)(4). Doug and Aaron discuss attribution: what is it, and why is it important; Section 318; the history of ‘downward attribution’; the perceived abuses under Section 958(b)(4), including how attribution rules affect CFC determinations, and how those determinations affect ‘toll charge’ calculations and Section 267(a) downward determinations; legislative history, congressional intent, and the potential for legislative fixes to the perceived abuses; how the recently proposed regulations affect downward attribution; when the proposed regulations will become effective, and how taxpayers can retroactively rely on the regulations; and finally, relief provided by Revenue Procedure 2019-40 - how it may allow for using alternative information, and its impact on compliance considerations like Form 5471 filings.

    • 32분

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