Shows
Cross-border Tax TalksUS CAMT Proposed Regs: You are no Pillar TwoDoug McHoney (PwC’s International Tax Services Global Leader) is joined by returning guest Aaron Junge, an International Tax Partner in PwC’s Washington National Tax Services Practice. Aaron served as Tax Counsel to the US House of Representative during the passing of the Tax Cuts and Jobs Act in 2017. Doug and Aaron briefly discuss the College World Series held in Aaron’s hometown of Omaha, before delving into the Corporate Alternative Minimum Tax (CAMT) proposed regulations. Specifically, they discuss Adjusted Financial Statement Income (AFSI), how the rules affect large domestic and foreign investment funds and partnerships, the open commen...2024-10-1141 minCross-border Tax TalksSweet Child O'Mine: Inbounding Intangibles to the USDoug McHoney (PwC's International Tax Services Global Leader) is joined by Aaron Junge, PwC National Tax Services International Tax Partner, and former Tax Counsel for the House of Representatives during the enactment of the Tax Cuts and Jobs Act. They discuss the historical perspective of the Section 367(d) rules beginning back in 1984, the recent regulations, and how we got here. Doug and Aaron touch on Section 367(d)’s original intended purpose, how the changes that occurred during TCJA changed intangible property (IP) ownership for US MNC’s (the carrot and the stick metaphor), the possible tax treatments of the repa...2023-06-0741 minCross-border Tax TalksThe IRA and Book Minimum Tax: Not a Pillar Two PodcastDoug McHoney (PwC's Global International Tax Services Leader) is joined by Aaron Junge in Westminster Studios. Aaron is International Tax Partner in PwC’s Washington’s National Tax Services and was previously Tax Counsel in the House Ways and Means Committee during the Tax Cuts and Jobs Act implementation. Doug and Aaron discuss the corporate alternative minimum tax (also called the ‘Book Minimum Tax’) and other Inflation Reduction Act tax provisions, which President Biden signed into law on August 16. More specifically, they cover the BMT effective date and its scope, what are applicable corporations, changes to the aggregat...2022-08-1748 minCross-border Tax TalksExtraordinary Considerations: the 245A DRD regulationsDoug McHoney (PwC's US International Tax Services (ITS) Leader) and Aaron Junge (ITS Partner in PwC's Washington National Tax Services practice) discuss the recently-released final and proposed dividends received deduction (DRD) regulations under Section 245A. Doug and Aaron discuss: Aaron's background as Tax Counsel for the Committee on Ways and Means in the US House of Representatives and how this experience proves valuable in the private sector; the background and architecture of Section 245A; important topics included in the final and proposed DRD regulations including hybrid dividends, extraordinary dispositions (ED), and extraordinary reductions (ER); topics not fully contemplated in...2020-10-0238 min