Shows
Cross-border Tax TalksCareers in tax: Two international tax titansDoug McHoney (PwC’s International Tax Services Global Leader) is joined by Mike Urse and Calum Dewar, both retiring PwC International Tax partners with decades-long careers in cross-border tax. Mike served as PwC’s US ITS Leader, while Calum built his career across PwC UK and PwC US, specializing in European and global tax systems. Doug, Calum and Mike discuss the dynamic nature of international tax and the intellectual curiosity that drew them to the profession. They also reflect on the evolution of PwC’s international tax practice, consensus-driven leadership, and building high-performing teams. The trio shares stories on mentor...
2025-07-2936 minCross-border Tax Talks100th Episode Special: The evolution of global structuringDoug McHoney (PwC's US International Tax Services Co-Leader) is joined by Mike Urse, current International Tax Partner and former US International Tax Services Leader for the 100th episode of the Cross Border Tax Talks podcast. Doug and Mike discuss the changing world of international taxation, focusing on the current status of holding companies, finance companies, and Intangible property companies. Mike provides insights and analysis from almost 40 years of international tax experience and sheds some light on the future state of play.
2022-06-2237 min
Tax ReadinessHow to comply with the new final stewardship regulationsThe December 2020 final foreign tax credit regulations introduced a stock-based asset apportionment methodology for all taxpayers. But given the timing of these final regulations, many taxpayers were forced to estimate their stewardship for provision purposes using the asset apportionment methodology used for interest expense. Since many taxpayers are past provision season, now is the time to consider how, under the new regulations, you can lower stewardship expenses, which may in turn improve your ETR, your foreign tax credit position and your foreign-derived intangible income (FDII) outcome.On this podcast, our international tax and transfer pricing specialists discuss:
2021-05-2454 minTax ReadinessKey highlights of the 2020 final and proposed foreign tax credit regulationsIn this podcast, PwC professionals hold a detailed discussion on the Foreign Tax Credit (FTC) regulations. The Final Regulations finalize, among other provisions, the previously proposed FTC regulations and clarify several aspects of the new FTC regime, including the allocation and apportionment of certain deductions and creditable foreign taxes. Additionally, the Proposed Regulations modify and re-propose provisions of the 2019 Proposed Regulations regarding the allocation of foreign income taxes related to disregarded payments and propose new rules the allocation and apportionment of certain deductions, among others. Featuring:Pat Brown, Washington National Tax Services Co-LeaderNinee Dewar, Principal, International T...
2020-11-0550 minCross-border Tax TalksYou down with FTC? The new Foreign Tax Credit regulationsDoug McHoney (PwC's US International Tax Services (ITS) Leader) and Mike Urse (ITS Partner in PwC's Washington National Tax Services practice) discuss the recently released final and proposed foreign tax credit (FTC) regulations. Doug and Mike (who participated in our inaugural CBTT podcast over two years ago) go deep on interest, stewardship, and research and development (R&D) expense apportionment under the final FTC regulations; the importance in modeling potential retroactivity of the R&D regulations; the intricacies in allocating and apportioning foreign taxes; foreign tax redeterminations under Section 905(c); the 'disregarded payment rule' under the proposed regulations; how...
2020-10-2342 min