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Too many practitioners and service providers overlook foundational marketing strategies, focusing instead on trendy tactics like social media reels.Broken or missing foundations are the biggest reason people find themselves doing all this marketing that is going nowhere. It's not bringing in clients, it's bringing more frustration and burnout.When you understand how these simple foundations can be powerhouses when it comes to making your marketing work - then you understand the power they have. Listen to this episode as Kathy C shares how the 10 marketing foundations for success (Pillar One of Marketing) can shift everything. Do not miss the simple, oh-so-simple, examples of how small fixes had big results for some of her clients. You will be saying 90 more bookings in 30 days because of …what??? Yes, 90! Hit play and get ready to shift your focus to marketing that matters and gets you clients! You can access the shownotes at http://marketingyourprivatepractice.com/135Book your free marketing review with Kathy C here - https://www.pepperitmarketing.com/review Click here to send Kathy a text message about this Episode
Chris breaks down the demise of the global tax scheme championed by Biden, Yellen, and European nations, highlighting its potential harm to American businesses. He explains how the OECD's "Pillar One" and "Pillar Two" would have unfairly targeted U.S. tech and pharmaceutical companies while imposing a 15% minimum global tax rate. www.watchdogonwallstreet.com
Part 1 of the Catechism—the first pillar—is the longest part of the four parts of the Catechism, and arguably the most foundational. Fr. Mike sits down with Jeff Cavins to discuss the big picture behind this important pillar and prepare us for the journey ahead. This episode has been found to be in conformity with the Catechism by the Institute on the Catechism, under the Subcommittee on the Catechism, USCCB. For the complete reading plan, visit ascensionpress.com/ciy Please note: The Catechism of the Catholic Church contains adult themes that may not be suitable for children - parental discretion is advised.
Labour's foreign affairs spokesperson has called AUKUS a 'China containment strategy' - which Labour wants no part of. At the party conference, leader Chris Hipkins announced no future Labour Government would be involved in the tri-lateral security deal. David Parker says New Zealand should plot a path between the superpowers. He's confirmed Labour would withdraw from the deal if the current Government signs up. "In terms of the practicality of that - very little will have happened by then. Even the Pillar One submarines that are nuclear powered that Australia's purchasing - they don't arrive by the 2030s." LISTEN ABOVESee omnystudio.com/listener for privacy information.
Doug McHoney (PwC's International Tax Services Global Leader) is joined by Rohit Kumar, PwC's National Tax Co-leader and former deputy chief of staff to Senator Mitch McConnell (R) to discuss the US election results. Doug and Rohit cover what the republican-controlled House, Senate and Presidency means for tax reform, why 2025 will be a year for significant “must-pass” tax legislation, the role the federal debt and budget deficit will play, the potential implementation of tariffs, the fate of the OECD's Pillar One and Two, as well as how the new administration could approach digital services taxes (DSTs).
Jim and Ray welcome Charlie Edel, Australia Chair at the Center for Strategic and International Studies, about the significance of AUKUS--a trilateral security pact between Australia, the UK and the US--focusing on its implications for defense and technology collaboration in the Indo-Pacific region. Their discussion covers the origins of AUKUS, its strategic importance, the controversies around "Pillar One" (nuclear submarine production), and the challenges and potential for expanding partnerships beyond the three countries in "Pillar Two" (advanced technology cooperation). The conversation then moves on to the need for building enhanced deterrence capabilities to meet the growing China threat, and the evolving nature of defense technology collaboration.
This Day in Legal History: Anita Hill Testifies in Clarence Thomas Confirmation HearingOn October 11, 1991, law professor Anita Hill testified before the U.S. Senate Judiciary Committee during the confirmation hearings for Supreme Court nominee Clarence Thomas. Hill, who had worked under Thomas at the Department of Education and the Equal Employment Opportunity Commission (EEOC), accused him of harassment. Her testimony detailed allegations of inappropriate behavior by Thomas, igniting a national conversation about sexual harassment in the workplace.The hearings were televised and widely watched, drawing public attention to issues of power dynamics and gender in professional settings. Hill's testimony was met with intense scrutiny, and she was questioned by the all-male committee, led by Senator Joe Biden. Despite the controversy, the Senate ultimately confirmed Thomas to the Supreme Court by a narrow vote of 52-48.Hill's courage to speak publicly about her experiences had a profound and lasting impact. It helped raise awareness of sexual harassment and workplace rights, influencing the way such cases were viewed and addressed in the years to come. Her testimony is often seen as a pivotal moment in the evolution of the #MeToo movement, decades before it formally emerged.Donald Trump's legal troubles are far from over, with seven significant cases involving him still in the lower courts. These include two federal criminal cases, two state-level criminal prosecutions, and three civil lawsuits. The federal criminal charges, pursued by Special Counsel Jack Smith, focus on Trump's attempts to overturn the 2020 election and his retention of classified documents. If Trump regains the presidency, he may try to pardon himself or have the Justice Department drop these cases. However, state criminal charges, such as his conviction in New York over hush money payments and the Georgia election interference case, are beyond the reach of a presidential pardon.Civil cases against Trump include a New York fraud judgment related to his business practices and two defamation lawsuits from writer E. Jean Carroll. If Trump loses the 2024 election, these cases are likely to proceed and could eventually reach the Supreme Court. The Court has already ruled that former presidents have immunity from prosecution for actions taken as part of their official duties. The outcome of these cases, particularly any involving the Court, may depend heavily on the results of the November election. If Trump wins, the state cases will at least ostensibly remain–but it is likely that his administration would move to end some or all of the federal cases against him. Election may decide if Trump's legal woes reach US Supreme Court or wither | ReutersOn October 10, 2024, Boeing filed an unfair labor practice charge with the National Labor Relations Board against the International Association of Machinists and Aerospace Workers, the union representing around 33,000 striking workers on the U.S. West Coast. The strike, which has lasted four weeks, involves workers at Boeing's factories, including its facility in Renton, Washington. Boeing accused the union of failing to negotiate in good faith, alleging a pattern of bad faith bargaining and spreading misinformation to union members about the status of negotiations. This comes amid an ongoing labor dispute, with Boeing workers demanding better terms, while the company attempts to resolve the strike and resume production. The outcome of the charge could influence future labor negotiations between Boeing and the union.Boeing files unfair labor practice charge against striking union | ReutersItaly is considering expanding its digital services tax (DST) in the 2025 budget, which could reignite trade tensions with the United States. The DST, originally introduced in 2019, imposes a 3% tax on revenue from digital transactions by large tech companies like Google, Meta, and Amazon, many of which are American. The tax currently generates around €400 million annually, but Italian policymakers are exploring ways to increase revenue by raising the tax rate or lowering the revenue thresholds for companies subject to the tax.The U.S. has consistently opposed unilateral DSTs, viewing them as unfairly targeting American companies, and previously threatened tariffs in response to similar taxes in Europe. Although a prior agreement prevented such retaliation, Italy's new DST expansion could bring this issue back to the forefront. If the U.S. imposes tariffs, it could harm key Italian industries like manufacturing and agriculture, potentially straining diplomatic relations and weakening Italy's influence in international tax reform discussions.Italy's move reflects frustrations over stalled global tax reforms under the OECD's Pillar One framework. While expanding the DST might provide short-term fiscal relief as Italy faces rising debt and inflation, it risks further damaging trade and diplomatic relations with the U.S.Italy's Digital Tax Gambit—Will US Trade Retaliation Follow? This is a public episode. If you'd like to discuss this with other subscribers or get access to bonus episodes, visit www.minimumcomp.com/subscribe
This TP Talks episode addresses Amount B of Pillar One, focusing on the OECD's February 2024 final report and subsequent June guidance.1Support the show
What is the central logic of AUKUS from a UK perspective?How does AUKUS contribute to European security?How does AUKUS fit into UK defence interests and strategies in the Indo-Pacific?In this episode, Damian Parmenter joins Rory Medcalf to discuss the UK perspective on AUKUS: the strategic environment, Pillar One operational specifics, diplomatic engagement and legislation, and progress on Pillar Two.Damian Parmenter CBE is Director General AUKUS at the UK Ministry of Defence. Professor Rory Medcalf is Head of the ANU National Security College. His professional experience spans three decades across diplomacy, intelligence analysis, think tanks, journalism and academia. Show notes The undergoing UK Strategic Defence Review Australian National Defence Strategy British SSN involved in search for Malaysian Airlines flight MH370 US International Traffic of Arms Regulation Recent AUKUS agreement tabled in Australian parliament We'd love to hear from you! Send in your questions, comments, and suggestions to NatSecPod@anu.edu.au. You can tweet us @NSC_ANU and be sure to subscribe so you don't miss out on future episodes. The National Security Podcast is available on Acast, Apple Podcasts, Spotify, and wherever you get your podcasts. Hosted on Acast. See acast.com/privacy for more information.
This Tax Section Odyssey podcast episode takes a deeper dive into the Organisation for Economic Co-operation and Development's (OECD) initiative on Base Erosion Profit Sharing (BEPS) 2.0 which sets to reform the internation tax system with Pillar 1 and 2 tax regimes. In addition to the complexity of such international regulations, the political landscape for U.S. implementation is uncertain, and potential action is needed from Congress. Cory Perry, Principal, National Tax — Grant Thorton Advisors, and Vice Chair of the AICPA's International Technical Resource Panel (TRP), highlights that while many U.S. companies may not face larger tax bills if these regimes are adopted in the U.S., the administrative and compliance challenges are significant. The AICPA has submitted comment letters to the OECD, Treasury, and the IRS, focusing on simplification and clarification of rules. AICPA resources OECD BEPS 2.0 - Pillar One and Pillar Two — The OECD BEPS 2.0 sets out to provide a tax reform framework allowing for more transparency in the global tax environment. What you need to know about BEPS 2.0: Pillar One and Pillar Two | Tax Section Odyssey — The OECD BEPS 2.0 project is an international effort to reform the international tax system that addresses transfer pricing, profit allocation and tax avoidance. Advocacy Comments to Treasury on tax issues of OECD Pillar Two, Feb. 14, 2024 Comments to Treasury on Amount B of OECD Pillar One, Dec. 12, 2023 Other resources OECD BEPS — Inclusive Framework on Base Erosion and Profit Sharing For a full transcript of the episode, see Tax Section Odyssey on the AICPA & CIMA website.
Over the next three episodes, we explore some of the details of the Online Summit Program, and how we help hikers get fit, strong and resilient for their adventures :) This episode covers the first Pillar of the Program - Personalised Training. Want to learn more about the program? Book a chat with our team here: https://www.summitstrength.com.au/apply.html
A review of the week's major US international tax-related news. In this edition: US Supreme Court ends court deference to agency interpretations of ambiguous laws, including tax laws – US House Republican Tax Team on global competitiveness to hold first field meeting with stakeholders on 8 August, White Paper to follow – IRS will address DCL income allocation rules in context of BEPS Pillar Two global minimum tax jurisdictional tax blending – US, Switzerland sign new FATCA Model 1 agreement – US Treasury and OECD officials offer insights on BEPS 2.0 Pillar One and Pillar Two project.
Countries are under pressure to finalize and sign the text of the OECD's multilateral tax treaty, one part of the international tax deal known as Pillar One, by the end of June. Several OECD officials, including Manal Corwin, director of the organization's Center for Tax Policy and Administration, have reported significant progress on finalizing the document. But negotiations have hit a snag. The problem area is treatment of another part of Pillar One, known as Amount B, that's meant to simplify the way businesses value intercompany marketing and distribution transactions. The US and India, in particular, have butted heads over whether the measure should be mandatory. In this week's episode of Talking Tax, Bloomberg Tax reporter Lauren Vella sits down with Dr. Santiago Gomez Cifuentes, head of congressional affairs at the Colombian Embassy in Washington, to talk about progress made on the Organization for Economic Cooperation and Development-led deal and what's holding back the completion of Pillar One. Gomez Cifuentes is in close contact with the Colombian delegation to the OECD, and serves as a go-between representing Colombian interests in conversations with US lawmakers. They also talk about Colombia's interest in the US Inflation Reduction Act and tax incentives that could boost mineral exports from Latin American countries. Produced by Matthew S. Schwartz.
The OECD BEPS 2.0 project consists of two pillars. Pillar One applies to the biggest and most profitable multinational enterprises and reallocates part of their profit and taxing rights to the countries where they sell their products and services. Pillar Two introduces a global minimum corporate tax of 15% to prevent tax avoidance and base erosion. The U.S. has not yet adopted the OECD project into its tax system, but it will still impact U.S. multinational businesses that operate abroad. Practitioners need to know about the OECD project because it is a major change in the international tax system that will affect many multinational enterprises and their tax compliance. AICPA resources OECD BEPS 2.0 - Pillar One and Pillar Two — The OECD BEPS 2.0 sets out to provide a tax reform framework allowing for more transparency in the global tax environment. Advocacy Comments to Treasury on tax issues of OECD Pillar Two, Feb. 14, 2024 Comments to Treasury on Amount B of OECD Pillar One, Dec. 12, 2023 Other resources OECD BEPS – Inclusive Framework on Base Erosion and Profit Sharing
Doug McHoney (PwC's International Tax Services Global Leader) is in São Paulo, Brazil for the first Latin American recording of the CBTT with PwC Brazil's International Tax Leader Dr. Romero Tavaras. Doug and Romero discuss what makes Brazil's tax system so unique – from its transfer pricing rules to its full inclusion regime. They also dive into expected Brazilian tax changes, the many acronyms that make up the indirect tax system, Pillar One, and what effect Pillar Two will have on Brazil's taxpayers.
Discover Life Church stands on four pillars: Christ, Community, Cultivate, Commission. Step one for everyone should be finding Christ! If we want to make it hard for people to go to hell, we have to make it easy for them to go to church. Christ is the most valuable pillar!
#支柱一 #Pillar 1 #全球利潤分配稅制 #跨國企業 OECD公布支柱一中「金額B」的更新徵求意見稿,旨在透過以「訂價矩陣(pricing matrix)」中所規定同意之報酬,以簡化特定基本行銷和銷售活動的移轉訂價,並將這些報酬歸予所得來源國。影片說明Amount B的適用交易(Qualifying Transactions)、三步驟判斷常規交易報酬(Determining the arm's length return)、訂價矩陣圖及對應所有產業適用的貝里比率(Berry ratio)設定利潤上限範圍(貝里比率1.05~1.5)。 歡迎成為資誠會員:https://pwc.to/2V8Lh8v
Michael Plowgian, who in December left his role as deputy assistant secretary for international affairs at the Treasury Department, had an eventful stint at the department. The former top OECD negotiator for the US started at Treasury in October 2021 as a counselor right around the time over 140 countries agreed to the global tax deal. Since then, Plowgian has been a part of large steps in the deal's progression—from tranches of Pillar Two rules to the release of a draft multilateral treaty text that would reallocate large multinational companies' residual profits to market jurisdictions. The international tax pact consists of two parts: a reallocation of large multinational companies' residual profits, known as Pillar One, and a 15% global minimum tax, known as Pillar Two. The work at the Organization for Economic Cooperation and Development, and therefore the Treasury, isn't done. Plowgian talked to Bloomberg Tax reporter Lauren Vella about what's next for the deal, how the multilateral treaty might fare in Congress, and what red lines the US won't cross in further negotiations with other countries. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
Part 1 of the Catechism—the first pillar—is the longest part of the four parts of the Catechism, and arguably the most foundational. Fr. Mike sits down with Jeff Cavins to discuss the big picture behind this important pillar and prepare us for the journey ahead. Unlock the full experience of The Catechism in a Year (with Father Mike Schmitz) with the Ascension App! (https://ascensionpress.com/pages/ascension-app?_branch_match_id=1248288113491054729&utm_source=youtube&utm_medium=marketing&_branch_referrer=H4sIAAAAAAAAA8soKSkottLXz8nMy9ZLLE5OzSvOzM%2FTTSwo0EvOz9X3CKtwCktMDfB1SQIAklUiuCoAAAA%3D) Get access to an interactive reading plan, the complete text of the Catechism, episode transcripts, summaries, and more. This episode has been found to be in conformity with the Catechism by the Institute on the Catechism, under the Subcommittee on the Catechism, USCCB. For the complete reading plan, visit ascensionpress.com/ciy Please note: The Catechism of the Catholic Church contains adult themes that may not be suitable for children - parental discretion is advised.
Over the past six months, the OECD has released multiple documents with more details on parts of the international tax deal agreed to by over 140 countries in 2021. But even with the additional clarity from the Organization for Economic Cooperation and Development, there are still fundamental questions about key parts of the deal—such as a simplified transfer pricing method, known as Amount B—that remain. The tax agreement comprises two parts: a reallocation of large multinationals' residual profits, known as Pillar One, and a 15% global minimum tax, known as Pillar Two. Alan McLean, chair of Business at OECD's tax committee, talked to Bloomberg Tax's Lauren Vella about how the deal's developments impact some of the world's largest multinational corporations, and what's most concerning to companies as the world moves forward with parts of the tax pact in 2024. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
Doug McHoney (PwC's International Tax Services Global Leader) is at PwC's Global Tax Symposium in Rome, where he's joined by Will Morris. Will is PwC's Global Tax Policy Leader, and on Will's last visit to the podcast, he covered FSR, the Foreign Subsidies Regulation. On this podcast, an exciting and familiar topic - Pillar Two! Doug and Will discuss generally how the Pillar Two process has been going. They wonder how tax authorities and courts will administer and adjudicate in their jurisdictions, and what will become of the potential FAQs and future administrative guidance from the OECD. They then discuss the recent EC guidance, and whether countries will be able to bring in the OECD guidance retroactively. Finally, Doug and Will touch on how business have participated thus far in the process.
African countries face several challenges in negotiating the global tax deal involving more than 140 countries at the Organization for Economic Cooperation and Development. The agreement includes reallocation of the residual profits of large multinational companies to market jurisdictions, known as Pillar One, and a 15% global minimum tax, known as Pillar Two. On this week's episode of Talking Tax, Bloomberg Tax senior reporter Danish Mehboob speaks with Logan Wort, executive secretary at the African Tax Administration Forum, about why developing countries feel they don't have a seat at the table for these negotiations and why some would prefer to have the project play out at the United Nations rather than the OECD. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
Doug McHoney (PwC's International Tax Services Global Leader) is at PwC's Global Transfer Pricing Conference where he's joined by Giorgia Maffini. Giorgia is part of PwC's Global Transfer Pricing team in London and was previously the Deputy Head of the Tax Policy and Statistics Division at the OECD. Doug and Giorgia discuss why taxpayers should care about Pillar One, starting with the basics - what is Pillar One and how does it work with Pillar Two? They discuss the complexities, scope and impacts of both Amount A and Amount B. Also the timing, economic impact, and what's next. Finally, they address what might happen with digital services taxes and what companies should do next.
Peter is joined by John Hemmings from the US and Malcolm Davies from Australia to talk about AUKUS. Since the security agreement was signed in September 2021, taking many people by surprise, the security situation in the Indo Pacific has deteriorated. But progress on both Pillar One and Pillar Two activities has not been rapid. Indeed, it sometimes feels like wading through treacle – despite the PR hype and political speeches. Peter, Malcolm and John try to identify the hurdles and challenges to progress and where the solutions might lie. There are also a series of warnings that lie within: It may be that if we don't give industry a big enough role, domestic and political change in 2024 could put an end to the partnership before it delivers. This episode is sponsored by Leidos. For more information on what Leidos do in national security and defense, go to https://www.leidos.com/company/our-business/defense
2023 has been a rollercoaster in the world of international tax and transfer pricing - and 2024 looks to be more of the same. As 2023 draws to a close, we delve into the key tax initiatives that have shaped the transfer pricing landscape over the past year. This episode navigates through topics ranging from the OECD's Pillar One and Pillar Two, to the adoption of the OECD Guidelines by Brazil and the impact of economic uncertainty and evolving business models on transfer pricing. Our host Brittany Hardin Tanguay is joined by Jessie Coleman, a Principal in Washington National Tax, to discuss highlights from the previous year, as well as the challenges and opportunities that lie ahead in the realm of transfer pricing.
A review of the week's major US international tax-related news. In this edition: US Congress passes CR to fund government past 17 November deadline – Government officials offer update on CAMT, stock buyback excise tax and PTEP regs – Chilean Congress approves US-Chile tax treaty with US reservations – US proposing new deadline for signing BEPS 2.0 MLC on Amount A of Pillar One – 48 countries pledged to implement OECD Crypto-Asset Reporting Framework by 2027.
A monthly review of US international tax-related developments. In this edition: US Congress to take up appropriations bills, consider US-Taiwan tax relationship – IRS proposes updating consolidated returns regulations, discarding unnecessary guidance – IRS issues proposed regs on broker reporting requirements for digital asset sales and exchanges – Cryptocurrency stakers must include rewards in gross income upon gaining control – Russia suspends US-Russia, other tax treaties – Progress reported on BEPS Amount A, Pillar One, further work on Pillar Two safe harbors – Global minimum tax filing simplification possible, OECD official says – UN releases final report on international tax cooperation.
In this TP Talks episode, Kristina Novak (Principal in PwC's US National Tax Practice), Kartikeya Singh (Principal in PwC's US National Tax Practice), and Giorgia Maffini (Transfer Pricing and Tax Policy Director with PwC UK) discuss the OECD's recent Public Consultation document on Amount B of Pillar One and the details of the progress made since the December 2022 consultation.Timestamps:1:17 - What is Pillar 1 and what is Amount B under Pillar 1?3:30 - Can you bring our listeners up to speed on what has happened since the December 2022 consultation document on Amount B?5:23 - Can you provide more detail on what was covered in the July consultation document and how the draft may have taken previous input submitted in response to the December consultation document? 12:32 - There seems to be a point of disagreement among the countries on the two scoping alternatives (alternative A and alternative B). Can you explain why that is and tell us more about the different alternatives?18:26 - There appears to be an overly meticulous justification for obstructing a project with potentially significant benefits; what are your thoughts on that?20:30 - The stated goals for Amount B were certainty and simplicity. Are we on the road to achieving those goals, and does Amount B actually address the real underlying causes of all the controversy related to routine distributors? 25:06 - Regarding the July consultation document, you had mentioned that the Pricing Matrix is the “core” of Amount B. Can you explain how it works?31:57 - What questions have you been getting from taxpayers since the release of the July consultation document? What concerns them the most?35:30 - What are some takeaways that you can offer our listeners?Support the show
July was a big month for the OECD, marking its release of a tranche of documents detailing progress on the global tax deal agreed to by more than 130 countries in 2021. The agreement includes reallocation of the residual profits of large multinational companies to market jurisdictions, known as Pillar One, and a 15% global minimum tax, known as Pillar Two. On this week's episode of Talking Tax, Bloomberg Tax reporter Lauren Vella speaks with Manal Corwin, director of the OECD's Center for Tax Policy and Administration, about nuances of the latest guidance and next steps to move the deal forward. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
If Amount B is supposed to simplify transfer pricing, why does it seem so complicated? Listen as we break it down. In this episode we explore the major announcement regarding Amount B released this week by the OECD with our KPMG knowledge leader from London. On Monday July 17, we got the latest update from the OECD on its efforts to simplify transfer pricing through Amount B, part of its BEPS 2.0 initiative to address the tax challenges of digitalization. What will this mean for multi-nationals cross-border transaction, transfer pricing policy, and future transfer pricing planning? Will Amount B actually apply to digital businesses? With all of the news regarding Amount B, we will break down the announcement and address some of the potential implications.
A review of the week's major US international tax-related news. In this edition: US Supreme Court accepts case on constitutionality of Section 965 transition tax – US House to address Ways and Means tax package after July 4 recess – IRS announces stock buyback excise tax transition relief – OECD will soon release rules for simplifying Amount B in Pillar One.
In this episode of the “GILTI Conscience” podcast, Skadden partners David Farhat and Nate Carden, along with associates Eman Cuyler and Stefane Victor, discuss Pillar One's Amount B with Jessie Coleman of KPMG.In December 2022, the OECD issued documentation providing a much anticipated outline of Amount B, however, many uncertainties still remain surrounding scoping requirements and pricing.There is still much work to be done to address concerns around the drafted Amount B documentation and ensure the new framework will work for both developed and developing countries. However, many countries seem committed to making Amount B a success, including the U.S., as the Treasury has stated it's very open to input.
The OECD's global tax deal is approaching a milestone: The organization expects to see the release this summer of major remaining pieces of the agreement that have been under negotiation. But throughout the process, many developing countries have felt their concerns weren't sufficiently addressed, said Marlene Nembhard-Parker, a senior tax official in Jamaica who is also co-chair of the Inclusive Framework of 143 countries working on the global tax agreement. Meanwhile, the United Nations also has a new international tax effort in the works. That project isn't intended to duplicate or undermine the OECD's work, she said, but to "address the issues of legitimacy as to who is responsible for setting global tax rules." On this week's Talking Tax, Nembhard-Parker speaks about developing countries' perspective on the agenda and outcomes of the OECD and UN work, and why the commitment from governments to reach agreement on Pillar One creates a sense of "cautious optimism." Nembhard-Parker's remarks are part of a pre-recorded interview aired during the Bloomberg Tax Leadership Forum, held virtually Tuesday. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
In Sheri and Lori's book, Standing Room Only: How To Be THAT Yoga Teacher, we learn that there are five pillars to excellent teaching. In today's podcast, we dive into pillar one and kick off our series on the five pillars. Over the next four weeks, we'll e exploring what makes an excellent yoga teacher and how we can improve our personal practice and teaching technique. Check out the new book, Standing Room Only: How To Be That Yoga Teacher on Amazon!
Doug McHoney (PwC's International Tax Services Global Leader) is joined in Madrid by Edwin Visser, PwC's European Tax Policy Leader. Prior to joining PwC, Edwin was the Deputy Director General for Tax Customs Policy and Legislation and Director for Direct Taxes at the Dutch Ministry of Finance. One of the real challenges for tax professionals and advisors is the sheer volume of tax proposals from the European Union. Edwin and Doug discuss the numerous EU tax proposals, including the Carbon Border Adjustment Mechanism (CBAM), the Foreign Subsidies Regulation (FSR), Green Energy Credits, ATAD3. They also cover the EU's legislative process, flashback to the Common Consolidated Corporate Tax Base (CCCTB), then tackle Business in Europe: Framework for Income Taxation (BEFIT), the SAFE project, and the Debt-equity bias reduction allowance (DEBRA). They cap the episode with a check in on Pillar One and Pillar Two.
Our guest on Episode #49 of the TGG Podcast, in association with Hudl, is Pedro Marques, the Technical Director of Benfica's Academy. There's a strong case for saying that Benfica have the top Academy in Europe. They are the reigning UEFA Youth League champions (having beaten RB Salzburg 6-0 in the 2022 final), have the most profitable Academy in Europe (according to the CIES) and have recent graduates including Ruben Dias, Joao Felix and Bernardo Silva. SHOW NOTES => 02:30: Is there one thing that sets Benfica's Academy apart? 06:07: The importance of the Benfica Campus. Previously it was like "travelling with a house on your back" for players, parents and coaches. 08:56: Balance between being a development club and one that also wins trophies. 11:24: PILLAR ONE of the Benfica Academy = Scouting. 17:04: Admiring the work of Right 2 Dream, especially their character development and commitment to all children. 21:01: Overall there are 520 players in the system - 200 in the regional talent centres, 100 living in Lisbon and 220 living at the Benfica Campus. 26:45: Despite the success with South American players, the focus of the Academy is Portugal. 29:18: PILLAR TWO of the Benfica Academy = Methodology. 30:04: Broad base and diversity of activities at younger ages (futsal, dance, gymnastics, cage football) with more specialism at the older ages. 32:04: Playing model throughout the club. "It's not so much about the system, but principles & ideas - about intensity, taking the initiative, pressing high,regaining quickly & scoring lots of goals." 36:34: PILLAR THREE of the Benfica Academy = Competition. 41:02: PILLAR FOUR of the Benfica Academy = Opportunities. 43:17: Benfica Lab. 45:25: Instead of selling your stars, could you hold onto your best players in future and win the Champions League?
Since the publication of the OECD's Pillar One—Amount B consultation document, there have been many questions and disputes from businesses and tax leaders alike surrounding its application. This episode takes a closer look at ‘Amount B' and the tax implications it will have on multinational businesses reporting distribution activities.
Doug McHoney (PwC's US International Tax Services Global Leader) is joined by Pat Brown, International Tax Partner and co-Leader of the Washington National Tax Practice to look back at the very eventful and tortured 2022 year in international taxation. They cover topics including US Congressional activities, Treasury's 2022 regulations and guidance, recent international tax and transfer pricing rulings, and the progress made on Pillar One & Two.
Conversations surrounding transfer pricing practices rarely span to include the myriad regulations throughout Africa. However, across the continent, there are vast distinctions between countries that are thriving under new international tax rules and others that are struggling to keep up. Lolade Ososami, a partner and head of the tax team at Udo Udoma & Belo-Osagie, says that transfer pricing has grown and evolved in Africa over the last decade. When the OECD released the BEPS action plans in 2018, it had a huge impact on tax practitioners, particularly in Nigeria. Zach Pouga, a partner in the International Tax Group at Ernst & Young, encounters transfer pricing in nearly every aspect of his work. He frequently deals with BEPS 2.0, Pillar One and Pillar Two when advising his clients regarding their presence in Africa, as well as helping governments across Africa understand the complexity of new tax rules. In this episode of the GILTI Conscience podcast, Lolade and Zach join our hosts to dive into the evolving world of international tax throughout Africa. From how U.S. multinationals operating in Africa approach transfer pricing to how Africa-based companies and regional governments are branching out, Lolade and Zach explore the complexities of transfer pricing and international tax.
Part 1 of the Catechism—the first pillar—is the longest part of the four parts of the Catechism, and arguably the most foundational. Fr. Mike sits down with Jeff Cavins to discuss the big picture behind this important pillar and prepare us for the journey ahead. For the complete reading plan, visit ascensionpress.com/ciy Please note: The Catechism of the Catholic Church contains adult themes that may not be suitable for children - parental discretion is advised. This episode has been found to be in conformity with the Catechism by the Institute on the Catechism, under the Subcommittee on the Catechism, USCCB.
In this TP Talks episode, David Ernick (Transfer Pricing Principal in PwC's US National Tax Services practice) is joined by Osman Mollagee and Michael Butler (PwC Transfer Pricing Partners based in South Africa) to discuss the business environment in regions across Africa, the tax and transfer pricing landscape, general audit processes and avenues available with respect to dispute resolution, and what developing countries are looking for from Pillars One and Two of the OECD's global tax reform project.Support the show
In an effort to address tax issues surrounding the ever-growing digitalization of the global economy, the OECD proposed blueprint plans called Pillar One and Pillar Two. Though they were introduced in October 2020, implementation remains a challenge. In this episode of the GILTI Conscience podcast, Europe tax head James Anderson and London tax partner Alex Jupp join our hosts to discuss how the U.K. may be the first out of the gate in Europe to see some traction with potentially carrying out the Pillars. From international M&A compliance to political challenges and technical hurdles, James and Alex detail many of the uncertainties the Pillars face in today's climate, both in the U.K. and across the EU.Tune in to find out more about the future of Pillars One and Two in the international market.
Since coaching so many clients over the past ten years, I've identified several common themes and obstacles moms face that I address again and again. With the help of my business coach, I thought through the exact steps I take to help moms overcome these obstacles and mapped out my unique process that I'm now referring to as "The More Mama Method." In this episode of the podcast, I'm delving into the first of three pillars that make up my signature framework. Understanding this pillar is the foundation for creating strong, safe, trusting, and loving relationships when it comes to parenting. I can't wait to share it with you! Get full show notes and information at www.lessdramamoremama.com/225
In this TP Talks episode, David Ernick (Transfer Pricing Principal in PwC's US National Tax Services practice) is joined by Stephan Rasch (PwC Transfer Pricing Partner based in Munich) and Michael Shaw (PwC Transfer Pricing and Tax Disputes Director based in London) to discuss transfer pricing controversy in the EU and UK, touching on the audit environment, APAs, litigation trends and more. Support the show
Over the past decade, some of the biggest changes to the international tax framework have come out of the Paris-based OECD—from the worldwide crackdown on base erosion and profit shifting to the two-pillar plan to overhaul global tax rules. Pascal Saint-Amans, the man at the helm of the organization's tax division through those years, recently announced he would be stepping down from his role at the end of October. Bloomberg Tax's Isabel Gottlieb sat down with Saint-Amans to talk about what he's doing next, what it will take to get the tax deal's Pillar One over the finish line, and the future of international cooperation on environmental taxation. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
The global tax pact that's been agreed to by nearly 140 countries has run into some obstacles, but the new global vice chair of tax for EY thinks chances are good that the big changes the agreement calls for will ultimately be implemented. EY's Marna Ricker acknowledges that there's a lot of work still to be done on both of the key parts of the agreement—Pillar One, which would reallocate a chunk of the taxing rights on big companies' profits to other countries, and Pillar Two, which would impose a 15% global minimum tax. “I think this is going to be a really interesting window of time,” Ricker said. On this episode of Talking Tax, senior reporter Michael Rapoport discusses the OECD agreement and the new Inflation Reduction Act taxes with Ricker, who assumed her new post on Oct. 1. She's been with EY for 28 years, and had previously been vice chair of tax for EY Americas. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.
From concerns over tax compliance to adoption of the OECD's Pillar One and Pillar Two models, in this latest episode Deloitte leaders Albert Baker and Mike Steinsaltz sit down to discuss what's top on the agenda for more than 160 senior tax and finance executives from across the globe who participated in Deloitte's 2022 Global Tax survey: BEPS and beyond.
Discover how to develop the true shame-free commitment required for overcoming pornography. I'm sharing the conditioning and limiting beliefs that keep people stuck in their porn habit, and how you can move away from relying on shame and towards a porn-free life. Get full show notes and more information here: https://www.sarabrewer.com/blog/shame-free-commitment