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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

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    • 5.0, 1 betyg

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.

    FDII shades clearer: the final Section 250 regulations

    FDII shades clearer: the final Section 250 regulations

    Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Ninee Dewar (a Partner in PwC's Washington National Tax Services (WNTS) ITS practice) discuss the recently-released Foreign Derived Intangible Income (FDII) final regulations under...

    • 35 min
    The evolution of 'cut and paste': 40 years of tax policy

    The evolution of 'cut and paste': 40 years of tax policy

    Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Pam Olson (PwC's US Deputy Tax Leader and Washington National Tax Services (WNTS) Practice Leader) discuss Pam's storied career as she retires from PwC. Doug and Pam talk: life as a tax...

    • 41 min
    A conversation about race in the tax profession

    A conversation about race in the tax profession

    Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Stephen Mosha (an ITS Partner and leader of PwC's Northeast Tax practice) have a candid conversation about Stephen's life as a Black tax professional. Doug and Stephen discuss:...

    • 39 min
    DAC6 Update: the latest EU disclosure rules

    DAC6 Update: the latest EU disclosure rules

    Doug McHoney (PwC's US International Tax Services (ITS) Leader) and Maarten Maaskant (an ITS Partner and ITS Desk Leader) discuss the EU's mandatory reporting rules (EU Council Directive 2018/822, also known as 'DAC6.') Doug and Maarten cover: the...

    • 42 min
    Whirlpool Decision: the Tax Court analyzes 'branch rules'

    Whirlpool Decision: the Tax Court analyzes 'branch rules'

    Doug McHoney (PwC's US International Tax Services Leader) and Tom Quinn (a Partner in PwC's International Tax Services practice specializing in Value Chain Transformation) analyze the US Tax Court's recently issued decision in Whirlpool v. Commissioner. Doug and Tom discuss: the facts and organizational structure; the basic structure of Mexican maquiladoras; the importance of Luxembourg's permanent establishment (PE) rules in Whirlpool; the intricacies of the Section 954(d) 'branch rules,' including a discussion on Foreign Base Company Sales Income (FBCSI) and how 'check-the-box' elections interplay with the branch rules; the judge's rationale in the Whirlpool opinion; the difficulties in classifying inter-company transactions as 'sales' or 'activities'; the importance of policy considerations - in addition to technical analysis - during tax planning; the importance of transfer pricing principles in Whirlpool, with a focus on the necessity of inter-company documentation; how the Whirlpool decision might have been interpreted post-TCJA; and final takeaways for taxpayers in light of the Whirlpool decision.

    • 44 min
    US Tax Reform Update: The final anti-hybrid regulations

    US Tax Reform Update: The final anti-hybrid regulations

    Doug McHoney (PwC's US International Tax Services Leader) and Neil Edwards (a Partner in PwC's ITS practice) analyze recently released guidance on the 'anti-hybrid rules' under Section 267A. Doug and Neil discuss: the general overview of the regulation package; how the anti-hybrid rules in the US compare to the OECD's recommendations in 'BEPS 1.0'; how the anti-hybrid rules in the US compare to the anti-hybrid rules in the UK and Australia; changes between the final anti-hybrid regulations and proposed anti-hybrid regulations, including the interest-free loan provision, imported mismatch rules, notional interest deduction (NID) rules, rules regarding deemed branch payments, the definition of a 'fiscally-transparent entity,' and the narrowing the 'interest' definition; and the proposed anti-conduit regulations under Section 881.

    • 34 min

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