Shows
Cross-border Tax TalksUS Stock Buyback Tax: a funding conundrumDoug McHoney (PwC’s International Tax Services Global Leader) is joined by Nita Asher, International Tax Partner in PwC’s Washington National Tax Practice and former legislative counsel to the Joint Committee of Taxation during the enactment of TCJA in 2017. Doug and Nita focus on the Stock Buyback Excise Tax enacted under the Inflation Reduction Act. Doug and Nita walk through Notice 2023-2, the recently released procedural and technical regulations, including the elimination of the per se rule, the funding rule, and which other countries are considering similar rules. They also discuss how the excise tax could present a mult...2024-06-2636 minCross-border Tax TalksPlaying by House Rules: More analysis of the Ways & Means bilDoug McHoney (PwC's US International Tax Services Co-Leader) is back in Westminster Studios with Nita Asher (PwC International Tax Services Partner), who served as legislative council at the Joint Committee on Taxation from 2017 to 2018. Doug and Nita pick up from the previous podcast with Sherry Grabow, and discuss the legislative climate; covering, among other topics: the legislative process for tax reform, how this iteration of reform differs from 2017, granting of regulatory authority, impact of proposed changes to Section 163(n), the wholesale changes proposed to BEAT; clarification to foreign personal holding company income; and new foreign tax carryforward rules.2021-10-0844 min
Tax ReadinessTax Readiness: International tax planning post-electionIn this episode we discuss that multinationals should expect significant changes in the tax environment from both US and non-US governments and organizations like the EU and the OECD. Additionally, a likely increase in the corporate tax rate would have major impacts on the GILTI and FDII rates and calculations. This, combined with global tax measures mean that multinationals must consider their global tax structure. These next six months are crucial for data-driven analysis and planning in order to understand options and react.The replay of the Tax Readiness: International tax planning post-election webcast is available here.2021-05-1152 minCross-border Tax TalksUS tax reform 2.0? Biden's international tax campaign proposalsDoug McHoney (PwC's US International Tax Services (ITS) Leader) and Nita Asher (ITS Partner in PwC's Washington National Tax Services office) cover some of President Biden's campaign tax proposals. Doug and Nita discuss: the current state of Congress and the White House; President Biden's campaign proposals to increase the corporate and global intangible low-taxed income (GILTI) tax rates, move the GILTI determination to a country-by-country basis, eliminate the exemption for qualified business asset investment (QBAI), amend the base erosion and anti-abuse (BEAT) tax, and implement a minimum tax on global book income; how President Biden's proposals interact with the...2021-01-2242 min