Shows
Cross-border Tax TalksNew FTC Regs: Raise your creditability scoreDoug McHoney (PwC's US International Tax Services Co-Leader) is joined by Ninee Dewar, PwC International Tax Services Principal, to discuss the recently released 2022 proposed foreign tax credit (FTC) regulations. These regulations relax some of the stringent creditability requirements that were set forth in the 2021 final FTC regulations. Doug and Ninee dive into changes to the cost recovery requirement, the attribution requirement for withholding tax on royalty payments, and the definition of a reattribution asset for purposes of allocating and apportioning foreign taxes.2023-01-0934 min
Tax 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 TalksFDII shades clearer: the final Section 250 regulationsDoug 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 Section 250. Doug and Ninee discuss: the background of the Section 250 deduction and how the deduction interplays with both FDII and Global Intangible Low-Taxed Income (GILTI); how the final regulations compare to the March 2019 proposed regulations under Section 250, including various changes to the documentation rules and loss transactions; Ninee's advice for taxpayers to meet the substantiation requirement; the background of the 'ordering rule' and how the...2020-07-3135 minTax ReadinessFinal Section 250 RegulationsIn this podcast, Mike DiFronzo (PwC’s Washington National Tax Services ITS Leader), Ninee Dewar (PwC International Tax Services Partner), Kartikeya Singh (PwC Transfer Pricing Partner), and Karen Lohnes (PwC Mergers & Acquisitions Partner) discuss highlights of what the final FDII regulations cover, the new substantiation rules, deduction mechanics, FDDEI sales, FDDEI services, related party sales, and partnerships. Contacts: Mike DiFronzo, Ninee Dewar, Kartikeya Singh, Karen Lohnes2020-07-2759 min
How we do itNavigating the winding career roadRashmi Soans (International Tax Services - Financial Services director) interviews Ninee Dewar (International Tax Services Washington National Tax Services partner) about how to navigate and chart your own career course. They discuss the different paths that are presented along the way, evaluating the routes and then making sometimes difficult decisions to arrive at the best professional and personal destination.2019-09-1100 min