Cross-border Tax Talks

A regulatory balancing act: Recent US guidance

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Wade Sutton, International Tax Leader of PwC’s Washington National Tax Services practice and guest host of Cross-border Tax Talks. After Wade reflects on his previous experience at the US Treasury Department, he and Doug discuss four proposed regulation packages under the One Big Beautiful Bill Act (OB3): expense allocation for net CFC tested income (NCTI) and foreign-derived deduction-eligible income (FDDEI), FDDEI eligi

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When regs lose their deference: Three cases rewrite the tax playbook

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Laura Williams, an international tax partner in PwC’s Washington National Tax Services office and former branch chief in the IRS Office of Chief Counsel. Doug and Laura discuss the role of Treasury regulations, Section 7805(a), and the post-Loper Bright limits on agency deference and delegated authority. They explain why TCJA’s mismatched effective dates created a ‘donut hole’ and examine three recent regulation-validity

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Measure Twice, Elect Once: The Latest Section 987 Regs

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Laura Valestin, an international tax partner in PwC’s Washington National Tax Services office, who specializes in the taxation of financial transactions, including foreign currency. Doug and Laura discuss the proposed Section 987 regulations governing the new CFC election, beginning with the rule’s scope, history, and common QBU fact patterns. They explain how the election can turn off future Section 987 gain-or-loss comp

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Globalized State Aid: Understanding Europe’s Foreign Subsidies Regulation

Wade Sutton, PwC’s International Tax Leader for the Washington National Tax Services Office, fills in as host while Doug is away on assignment. Wade welcomes Will Morris, PwC’s global tax policy lead and former chair of the AmCham EU Tax Committee. In this episode, Wade and Will discuss the EU Foreign Subsidies Regulation (FSR). They cover its state-aid origins, reach into M&A and public procurement, and early enforcement record. The episode examines the European Commission’s recent assessme

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Portal Combat 2: Pillar Two compliance post-mortem

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Pat Coughlin, a Chicago-based tax director in PwC’s Quantitative Solutions and Technologies Practice within International Tax Services and a former Notre Dame running back. Doug and Pat discuss the June 30, 2026, Pillar Two compliance post-mortem, including PwC’s experience filing more than 50,000 returns with a success rate above 99%. They dive into how business rules and filing capabilities were built across dozens of j

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Japan Tax Update: Tea, Tariffs and Top-up Taxes

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Shin Yamaguchi, a tax partner at PwC Japan, the Japanese inbound tax leader, and host of the English-language podcast Dial in Japan. Doug and Shin discuss Japan’s current inbound and outbound investment environment, the role of supply-chain diversification and energy security in Japanese outbound strategy, and why Japan remains an active market for inbound acquisitions and carve-outs. They also explore Japan’s Pillar Two

Taiwan Update: Treaties, Tariffs and Top-Up Tax Turbulence

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Paulson Tseng, PwC Taiwan’s International Tax Services and Transfer Pricing Leader, the firm’s Human Capital Leader, and host of the Finance and Tax Cafe podcast. Doug and Paulson discuss Taiwan’s corporate tax framework, including the 20% corporate rate, foreign tax credit limits, withholding tax friction for services, and CFC rules; how inbound investment remains strong in semiconductors and R&D while outbound model

No strait answers: Energy shocks, AI stocks, and trade talks

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Dr. Alexis Crow, partner and Chief Economist for PwC US. Prior to joining PwC, Alexis taught at the London School of Economics. Doug and Alexis discuss the macroeconomic and geopolitical implications of the Iran conflict, including energy-market scarring, oil-price scenarios, fiscal supports, inflation pressures, and central-bank constraints. They also examine the durability of US growth, AI-driven investment, consumer de

Portal Combat: Pillar Two Forms, Deadlines, and the Fight for Certainty

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Will Morris, PwC’s Global Tax Policy Leader, at PwC’s Asia-Pacific Global Tax Symposium in Hong Kong. Will previously chaired the Business and Industry Advisory Committee (BIAC) Tax Committee for 10 years. Doug and Will discuss the acute uncertainty surrounding Pillar Two filing readiness as initial 2024 calendar-year deadlines approach, including the OECD’s May 18, 2026, common understanding document, GIR central filing,

Mexico tax update: Nearshoring, audits, and treaty twists

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Adriana Rodriguez, a PwC international tax partner based in Mexico City, for a discussion recorded at PwC’s International Tax Conference. Doug and Adriana discuss the core features of Mexico’s corporate tax system, including corporate income tax, withholding taxes, VAT, inflation adjustments, CFC rules, capital gains planning, and the impact of the multilateral instrument on treaty access. They also explore whether Mexico

Tariff Strike Zone: IEEPA Refunds, Audit Pressure, and Fragmented Trade

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Chris Desmond, leader of PwC’s US Global Trade Services practice and, as Doug notes, a ‘reformed transfer pricing partner.’ Doug and Chris discuss the current fragmented trade environment, why tariffs may remain a lasting feature rather than a short cycle, rising customs enforcement, the Supreme Court’s IEEPA decision and the operational complexity of securing refunds, and how companies should assess gross-versus-net refu

Lost in FX Translation: The latest 987 regs

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Laura Valestin, an International Tax Services Partner in PwC’s Washington National Tax Services practice, where she focuses on financial transactions. In this episode, recorded at PwC’s International Tax Conference in Carlsbad, Laura unpacks the latest Section 987 developments following Notice 2026-17. Doug and Laura discuss what Section 987 is, why it matters for foreign currency gain or loss in branch and disregarded en

Tariffs, Tensions, and Tightropes: A global risk tour

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Anja Manuel, co-founder and principal at Rice, Hadley, Gates, and Manuel LLC, a strategic consulting firm, and a former diplomat, author, and foreign policy advisor. Doug and Anja discuss the geopolitical forces reshaping cross-border business, including the Iran conflict and its implications for oil, shipping, Gulf investment, and AI infrastructure; China’s internal trajectory, tariffs, critical minerals, Taiwan, and sup

Pillar Two SESHion: ‘Simplified’ safe harbour

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Steve Kohart, a New York City-based international tax partner at PwC and former advisor to the OECD’s Center for Tax Policy and Administration. Doug and Steve discuss the January side-by-side agreement’s implications for US-parented multinationals, why Pillar Two remains relevant through QDMTTs, and how the CBCR transitional safe harbor bridges to the permanent simplified ETR safe harbor. They unpack what ‘simplified’ rea

OB3 Guidance: 4 big beautiful notices

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Wade Sutton, a PwC principal who leads the International Tax Team in PwC’s Washington National Tax Services Practice and previously served as Deputy International Tax Counsel at the US Department of the Treasury. Doug and Wade discuss late-2025 Treasury and IRS guidance implementing cross-border provisions in the One Big Beautiful Bill Act (OBBBA), focusing on transition and compliance mechanics that surface on 2025 retur

In Jeopardy: Sovereign wealth funds and Section 892

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Nils Cousin, an international tax partner in PwC’s Washington National Tax Services Practice, for his fourth appearance on the show. Doug and Nils discuss Nils’s April 2024 Jeopardy experience before pivoting to the 1916-era Section 892 exemption: how foreign governments, sovereign wealth funds, and public pension funds use it, and how ‘commercial activity’ and ‘controlled commercial entity’ rules can taint the benefit. T

Geopolitical reset: Stability and Agility in 2026

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Craig Stronberg, Senior Director on PwC’s Intelligence Team. Craig leads analysts focused on macroeconomic and geopolitical intelligence; he previously served in the Office of the Director of National Intelligence. Doug and Craig discuss why business and tax leaders should focus on the geopolitical landscape to understand its impact on cross-border business, including tax. Stability is the new bar for many businesses in 2

The Global Tax Journey: 2025 to 2026

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Pat Brown, an International Tax Partner in PwC’s Washington National Tax Services practice and Co-leader of the National Tax Office. Pat previously served as GE’s VP of Tax and Director of Tax Policy. Doug and Pat discuss highlights from 2025: the US day-one Pillar Two executive order and the OECD’s late-year side-by-side package; Section 899; the shifting of DSTs into the trade lane; and the expanding role of the UN for

Pillar Two: The Side-by-Side Package

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Beth Bell, a Principal in PwC’s Washington National Tax Services Policy Office. She previously served as a Senior Advisor to the US Treasury Department, Tax Counsel for the US House Committee on Ways and Means, and Policy Director and Tax Counsel in the United States Senate. Doug and Beth discuss the OECD’s January 2026 side‑by‑side package: why consensus formed, how the side‑by‑side and UPE safe harbors operate, and why

Pillar Two: Middle East Roundup

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Hanan Abboud, a Dubai‑based International Tax and M&A partner who leads PwC’s Pillar Two efforts across the Middle East. Doug and Hanan discuss the Cooperation Council for the Arab States of the Gulf (GCC) region’s corporate tax landscape, including country differences, Zakat as a covered tax, and the prevalence of withholding and treaty networks. They then map Middle East Pillar Two adoption: Bahrain’s QDMTT, Kuwait’