Podcasts about pillar two

Doug McHoney (PwC's International Tax Services Global Leader) is joined by Tom Patten, a London-based US International Tax Partner at PwC. Tom focuses on inbound investment into the U.S. and returns to the podcast for a timely discussion on Sections 891 and 899, two lesser-known but increasingly important provisions in the international tax landscape.  Doug and Tom discuss the resurgence of Section 891 in light of a January 2025 executive order that directs Treasury to identify discriminatory or extraterritorial foreign taxes. They cover how Section 891 operates, potential implications for non-US citizens, and its interaction with treaties. The episode then turns to proposed Section 899 and a new House proposal aimed at modifying the base erosion and anti-abuse tax (BEAT). Tom and Doug examine how these retaliatory measures differ, overlap, and might evolve. They close with practical advice for multinational taxpayers navigating an uncertain legislative environment and the future of Pillar Two negotiations. 

Doug McHoney (PwC's International Tax Services Global Leader) is joined by Dr. Romero Tavares, PwC Brazil's International Tax Leader and a professor of international tax law in São Paulo. Doug and Romero discuss the increasing intersection between Brazil's international tax policy and global trade dynamics, including the effects of recent US executive orders. They cover Brazil's high-tax corporate environment, its historically aggressive CFC-like full inclusion regime, and the country's rapid adoption of a qualified domestic minimum top-up tax (QDMTT). The conversation explores the political and policy rationale behind these moves, the anticipated redesign of Brazil's CFC regime, and the operational challenges multinationals face with the new OECD-aligned transfer pricing rules. Romero also breaks down Brazil's massive indirect tax reform and the country's potential shift to more internationally-aligned tax norms, while questioning the long-term viability of the undertaxed profits rule (UTPR) and Pillar Two's durability under changing geopolitical winds. 

Doug McHoney (PwC's International Tax Services Global Leader) is joined by Pat Brown, an International Tax Partner and Co-Leader of PwC's Washington National Tax Services practice. Together, they unpack the state of US corporate tax policy in 2025, analyzing how regulatory, legislative, and geopolitical forces could shape the next era of taxation. Doug and Pat dissect the final regulations issued in the closing days of the Biden administration, including the controversial disregarded payment loss (DPL) regulations, finalized and proposed digital content and cloud sourcing rules, and updates on corporate basis-shifting transactions. With a new administration in power, they explore whether these rules will stand, be modified, or be repealed entirely—and what this means for business certainty and planning. The conversation then pivots to legislative challenges, as the expiration of key provisions from the 2017 Tax Cuts and Jobs Act (TCJA) creates a ticking time bomb for tax policy.  Finally, they tackle the international tax front, where the US f administration responds to the OECD's Pillar Two and potential digital services tax (DST) retaliation under new proposals like Section 899.  

Doug McHoney (PwC's International Tax Services Global Leader) is joined by Steve Kohart, an International Tax Principal in PwC's New York City office and former advisor to the OECD's Center for Tax Policy and Administration. Doug and Steve discuss the OECD's latest administrative guidance on Pillar Two, covering key changes to transition rules, deferred tax asset adjustments, tax credits, and compliance burdens for multinational corporations. They dive into the OECD's focus on Bermuda and Switzerland, new anti-abuse measures, implications of the Qualified Domestic Minimum Top-up Tax (QDMTT), and the complexities of the new Globe Information Return (GIR). The conversation also explores the political and procedural challenges in implementing additional guidance, particularly in light of the new US administration's stance on Pillar Two. 

Deloitte Global partners Chad Hungerford and Chris Oates reveal the key practical challenges of pillar two implementation while finding cause for optimism and even excitement in an exclusive podcast with ITR.What motivates tax professionals to get up in the morning, and what keeps them up at night? Hungerford and Oates address these questions and more as they sit down with ITR commercial editor Phil Myers. The guest speakers draw on recent experience with tax authorities and clients to provide an inside track on the rapidly evolving pillar two landscape, with the significance of this moment resonating powerfully.“Whilst this is a challenge,” Oates says, “if you flip the coin, this is probably the most interesting new bit of tax legislation that has been introduced in my lifetime from a corporate perspective. And we see that reflected when we're having conversations.”The podcast explores the following areas:Emerging issues uncovered – Chad and Chris delve into the hurdles companies are finding;Priorities for companies – where businesses should be placing their focus at present;Common misconceptions – correcting widespread misunderstandings;M&A and growth plans – why pillar two must be factored in;Safe harbours and their future – why tax practitioners should “prepare for the worst and hope for the best”;Varying jurisdictional approaches – the “different flavours of implementation”;Technology transitions – whether now really is the right time to be considering new solutions; andThe outlook – where is pillar two heading?While the complexities and technicalities are addressed, the podcast also brings out the passion and excitement that drives tax professionals to tackle these challenges. The insights and practical advice on offer could help to arm you with the knowledge to navigate what, we are warned, could be a bumpy road ahead. As Hungerford says, “This is not something you can minor in – that you can spend a lot of time in every other area of tax and then just dabble with pillar two.”Listen in and dive deeper into pillar two.

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Tadd Fowler, Senior Vice President Treasurer and Global Taxes of Procter & Gamble. With nearly two decades at P&G, Tadd shares insights from his dual leadership in tax and treasury. Doug and Tadd discuss P&G’s approach to tax certainty, compliance in over 180 jurisdictions, and the strategic benefits of operating on a single ERP platform. They delve into US tax policy, the impacts of the Tax Cuts and Jobs Act, and P&G’s commitment to transparency and tax advocacy. Additional topics include preparing for Pillar Two compliance, managing ESG taxation, and adapting to evolving global tax landscapes.  See P&G’s Approach to Tax. 

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

A review of the week's major US international tax-related news. In this edition:  President-elect Trump to usher in new administration on 20 January – US House passes Taiwan tax bill – US officials address CAMT guidance – US, France issue statement on exchange of CbC reports for 2024 and 2025 – US officials comment on BEPS 2.0 project – OECD IF co-chairs provide status report on Pillar One Amount A and B – OECD compiling list of related-party transactions used to thwart Pillar Two global minimum tax – OECD releases three packages of BEPS Pillar Two 2.0 global minimum tax guidance.

Contributed by Christian Athanasoulas, Tax Practice Leader – Services, KPMG LLP, and Global Head of International Tax and M&A Tax, KPMG International; Janette Wilkinson, Partner, KPMG in the UK and Global BEPS Leader, KPMG International; Andy Baik, Tax Partner and BEPS Center of Excellence Leader, KPMG in Singapore; and Shawn Brade, National Service Line Leader, International Corporate Tax, KPMG in Canada, this podcast is created for those clients just beginning their journey or those that have taken steps forward but need to validate work completed to date.

Did you enjoy this episode? Text us your thoughts and be sure to include the episode name.In each episode of our Year-end toolkit series, our guests share insights on key areas of the year-end accounting and reporting process. The conversations are relevant for all finance teams, even if it's not year-end close time. And it's relevant even for those not engaged in the company's closing process – the episodes have something for everyone.In this next episode of our series, we discuss tax accounting and reporting reminders with Jennifer Spang, PwC's National Office income tax accounting leader. We cover a variety of tax accounting and reporting topics, including the impact of recent election results and the associated tax impacts expected in 2025.In this episode, we discuss:2:40 – Anticipated tax implications following the 2024 US election results10:50 – Pillar Two 17:36 – The FASB's disclosure standard 21:58 – Uncertain tax positions27:56 – Inflation Reduction Act credits and valuation allowances32:43 – Advice for year-end income tax accountingFor more information about key developments at the AICPA & CIMA conference, see our publication, 2024 AICPA & CIMA Conference: Current SEC and PCAOB Developments and see our publication, Accounting for Pillar Two: Frequently asked questions for the latest on the topic.Also, check out our other episodes in this miniseries:Year-end toolkit: Audit reminders for preparersYear-end toolkit: Year in review from the corner officeYear-end toolkit: Accounting and reporting reminders for 2025And please follow this podcast on your favorite podcast app for more episodes.Jennifer Spang is PwC's National Office income tax accounting leader, specializing in tax accounting under US GAAP and IFRS. She has over 30 years of experience helping companies in a variety of industries navigate complex tax accounting matters.Guest host Kyle Moffatt is PwC's Professional Practice leader, leading a team responsible for working with standard setters and regulators as well as delivering brand-defining thought leadership and educational materials. He also consults with engagement teams and audit clients on SEC reporting matters. Before PwC, Kyle spent almost 20 years with the SEC, most recently as Chief Accountant and Disclosure Program Director in the Division of Corporation Finance.Transcripts available upon request for individuals who may need a disability-related accommodation. Please send requests to us_podcast@pwc.com. 

Doug McHoney (PwC's International Tax Services Global Leader) is joined by Will Morris, PwC's Global Tax Policy Leader and former Director of Global Tax Policy at General Electric to look ahead to potential global tax policy changes. Will enlightens Doug about the confluence of tax and tariffs, digital services taxes (DSTs), the importance of communicating with the C-suite, the fate of Pillar Two, how the undertaxed profits rule (UTPR) could change, the role of the UN and global tax, and the potential for a US legislation as a reaction to DSTs and the UTPR. 

Doug McHoney (PwC's International Tax Services Global Leader) is joined by Andy Wiggins, PwC Partner based in the United Kingdom and PwC's Global Tax Accounting Services Leader to(birming)ham it up on the tax accounting implications of Pillar Two. Together they discuss, deferred accounting, the differences between US Generally Accepted Accounting Principles (GAAP) and International Financial Reporting Standards (IFRS), accounting implications of the qualified domestic minimum top-up tax (QDMTT), income inclusion rule (IIR), and undertaxed profits rule (UTPR), country by country reporting (CbCR), and transitioning from the full safe habor to GloBe rules. 

Doug McHoney (PwC's International Tax Services Global Leader) is joined by returning guest Matt Ryan, a PwC International Tax Partner based in London and leader of PwC UK's International Tax and Treasury Network. Doug and Matt discuss a selective list of Pillar Two issues and topics related to the UK Finance Bill 2024-25. They provide an update on the latest Pillar Two happenings, including the transposition of the June 2024 OECD Administrative Guidance into UK law, the potential for retroactive provisions, UK compliance requirements, the potential for changes in light of the US election, and what could be next. 

Doug McHoney (PwC's International Tax Services Global Leader) is joined by Stewart Brant, Managing Director in PwC's Tax Policy Services to discuss the latest Pillar Two developments. Doug and Stewart start off – after baseball of course – discussing the purpose of the Digital Tax Study Group. Then they cover the status of Pillar Two enactment in Europe, Asia, the Americas, the Pacific, the Caribbean, Middle East, and Africa. They also cover how different countries are applying the rules retroactively, the impact a Trump administration could have on Pillar Two, as well as what role the UN could play.

The Finance Minister has been quick to unpack some of Labour's announcements from over the weekend. At the party's annual conference, leader Chris Hipkins ruled out joining AUKUS - the security pact between Australia, the UK and the US. Finance Minister Nicola Willis has said this rejection of AUKUS feels 'premature'. "Let's remember it was Labour who started the discussions about Pillar Two of AUKUS back in 2021. No one's ever talked about joining the first pillar - but exploring how we could co-operate on technology was something Labour kicked off." LISTEN ABOVESee omnystudio.com/listener for privacy information.

Doug McHoney (PwC's International Tax Services Global Leader) is joined by Pieter Dere, Tax Partner in PwC Belgium, part of PwC's International Tax and Transfer Pricing Group, and PwC Belgium's Pillar Two leader. Doug and Pieter cover the latest Pillar Two developments in Belgium, including how Belgium is incorporating the latest Pillar Two administrative guidance, how tax authorities are preparing, advance tax payments, registration requirements, the Qualified Domestic Minimum Top-up Tax (QDMTT) return, the interaction of the Belgium patent box regime with Pilar Two, and the constitutionality of the Undertaxed Profits Rule (UTPR), among other topics. 

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.

Doug McHoney (PwC's International Tax Services Global Leader) is joined by returning guest Steve Kohart, an International Tax Partner in PwC's New York City office and former advisor to the Center for Tax Policy Administration for the OECD. They dive into Pillar Two with a refresher of the Qualified Domestic Minimum Top-up Tax (QDMTT), the Income Inclusion Rule (IIR), the Under Tax Profit Rule (UTPR), as well as the status of Pillar Two enaction across the globe, including in Puerto Rico. They also talk through how companies are approaching year-end, data readiness and tax compliance; Belgium's registration process; and several traps for the unwary, including the post-finalization of consolidated financial statements, purchase price accounting, hybrid arbitrage, and country-by-country safe harbor requirements. Finally, they discuss what makes a ‘good' credit for Pillar Two, the US R&D credit, the reverse consensus process for qualifying a QDMTT, permanent safe harbors, and what guidance to expect next. 

Doug McHoney (PwC's International Tax Services Global Leader) is joined by returning guest Aaron Junge, an International Tax Partner in PwC's Washington National Tax Services Practice. Aaron served as Tax Counsel to the US House of Representative during the passing of the Tax Cuts and Jobs Act in 2017. Doug and Aaron briefly discuss the College World Series held in Aaron's hometown of Omaha, before delving into the Corporate Alternative Minimum Tax (CAMT) proposed regulations. Specifically, they discuss Adjusted Financial Statement Income (AFSI), how the rules affect large domestic and foreign investment funds and partnerships, the open comment period, the similarities (and differences) between CAMT and Pillar Two, whether or not CAMT could be converted to a QDMTT, how the regulations impact adjustments for depreciation, and new foreign stock rules.  

Doug McHoney (PwC's International Tax Services Global Leader) is joined by returning guest Alex Voloshko, an International Tax Partner in PwC's Washington National Tax Services Practice where he specializes in value chain transformation and the tax implications of business operating models. Doug and Alex discuss how tax interacts with the broader business, the evolution of the tax operating model, business model reinvention, the importance of data, supply chain management, IP trends from the 2017 TCJA, and the potential impact of Pillar Two. 

What are the key challenges facing global tax policy today? Bob Stack, an international tax expert, explores the implications of the EU's adoption of Pillar Two and the potential for streamlining overlapping policies. He also addresses the issues that the US faces in global tax policy with the upcoming elections. In this insightful discussion, Bob dives into these pressing issues, drawing on his extensive experience at the US Department of the Treasury. He offers valuable insights into the OECD Inclusive Framework and the transformative Pillar Two.Links:https://taxfoundation.org/blog/pillar-two-unintended-consequences/https://taxfoundation.org/blog/global-tax-agreement/Support the showFollow us!https://twitter.com/TaxFoundationhttps://twitter.com/deductionpodSupport the show

What are the key challenges facing global tax policy today? Bob Stack, an international tax expert, explores the implications of the EU's adoption of Pillar Two and the potential for streamlining overlapping policies. He also addresses the issues that the US faces in global tax policy with the upcoming elections. In this insightful discussion, Bob dives into these pressing issues, drawing on his extensive experience at the US Department of the Treasury. He offers valuable insights into the OECD Inclusive Framework and the transformative Pillar Two.Links:https://taxfoundation.org/blog/pillar-two-unintended-consequences/https://taxfoundation.org/blog/global-tax-agreement/Support the showFollow us!https://twitter.com/TaxFoundationhttps://twitter.com/deductionpodSupport the show

Doug McHoney (PwC's International Tax Services Global Leader) is joined by returning guest Elizabeth Nelson, a Partner in PwC's Washington National Tax Services Practice to discuss the recently proposed regulations that address dual consolidated loss (DCL) rules as well an entirely new tax regime regarding disregarded payment losses (DPLs). Together they dive into the background of the US DCL rules, effective dates, foreign use, intercompany transactions, stock inclusions, mirror legislation, a new anti-avoidance rule, and of course the application of the DCL rules to Pillar Two.   

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.

Doug McHoney (PwC's International Tax Services Global Leader) is joined by Janice Mays (Managing Director in PwC's Tax Policy Services) who boasts  a 40 year career on the Hill including 22 years as the Democratic chief counsel and staff director for the House Ways and Means Committee, to discuss the upcoming US election's impact on tax policy.  Doug and Janice dive into the practice and procedures behind US tax policy, the upcoming US presidential election, and the key races to watch in the US Senate and House of Representatives. They also cover various election result scenarios, the key priorities for both Republicans and Democrats in a 2025 tax bill, and a potential US reaction to Pillar Two.

An Australian defence and foreign policy expert is cautioning New Zealand against joining AUKUS Pillar Two. Pillar Two of the security partnership between Australia, the UK and the US focuses on developing and sharing military technology between the group, including drones and hypersonics. Foreign Minister Winston Peters says New Zealand is "investigating" joining AUKUS Pillar Two, while the Prime Minister, Chrisopher Luxon told the Financial Times recently, New Zealand was "very open" to it. Former Prime Minister Helen Clark and former National and ACT Party leader Don Brash have teamed up to oppose any such move, saying it would be a radical change in NZ's foreign policy, which could upset our biggest trading partner, China. Australian National University Emeritus Professor Hugh White is in New Zealand at the invitation of Miss Clark and Dr Brash and joins Paddy Gower in studio.

The global tax deal and Pillar Two are shaking up the tax landscape worldwide, introducing a web of complexity and confusion. Today, we untangle the key aspects of these proposals, diving into the latest updates, compliance hurdles, and their ripple effects on industries and smaller nations. Join Daniel Bunn, President & CEO of the Tax Foundation, and Senior Economist Alan Cole, as they sit down with Kyle Hulehan to explore what the future holds for global taxation and what it means for the United States. Links: https://taxfoundation.org/blog/global-tax-agreement/https://taxfoundation.org/blog/pillar-two-flaw/https://taxfoundation.org/taxedu/glossary/oecd-pillar-2-global-minimum-tax/Support the Show.Follow us!https://twitter.com/TaxFoundationhttps://twitter.com/deductionpodSupport the show

Doug McHoney (PwC's International Tax Services Global Leader) is joined by Phil Ramstetter, International Tax Partner and former Tax Policy Consultant at Business at OECD (BIAC). Doug and Phil discuss the OECD's Administrative Guidance released in June 2024, including the deferred tax liability (DTL) recapture rule or five-year rule, the allocation of cross-border taxes, deferred tax accounting, transactions within the GloBE rules, entity classification and treatment, and the expectation of more OECD administrative guidance in the second half of 2024. 

Doug McHoney (PwC's International Tax Services Global Leader) is with Pat Brown, Washington National Tax Services Co-Leader, to discuss the complex state of international tax today and where the winds of Pillar Two are blowing. Doug and Pat bare their ankles and kick off the discussion with the state of international tax when Pat graduated law school.  They cover the increasing complexity of tax regimes, before diving into Pillar Two, the Undertaxed Payments Rule (UTPR), qualified CbC reporting, business concerns and struggles, the United Nations' role in international tax, and recently published Belgian Pillar Two registration requirements. 

Doug McHoney (PwC's Global International Tax Services Leader) and Peter Reilly (PwC International Tax Partner & Ireland's Tax Policy Leader) are at PwC EMEA's International Tax Academy in Prague to discuss Ireland's implementation of Pillar Two. Doug and Peter dive into why Irish policy makers agreed to adopt the Pillar Two regime, how Ireland is incorporating the OECD guidance, the potential effects on the Irish economy and current tax regime, the ways Irish multinationals are preparing, and the potential ramifications in the future. 

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

Rachel speaks to the leader of the opposition about the proposed repeal of Oranga Tamariki Act 77a, ministries hiring consultants after public sector cuts and the Labour Party's position on Aotearoa potentially joining Pillar Two of AUKUS. 

On What's Up with Chris Hipkins, Rachel speaks to the leader of the opposition about the proposed repeal of Oranga Tamariki Act 77a, ministries hiring consultants after public sector cuts and the Labour Party's position on Aotearoa potentially joining Pillar Two of AUKUS. The Bard of Bollix chats parrots on The Mind Trench. Boh Runga is in the studio for a conversation about Synthony Pride. Spycc of SWIDT chats about SWIDT Music Month. Whakarongo mai nei!

Doug McHoney (PwC's Global International Tax Services Leader) and podcast regular Calum Dewar (Principal, International tax services) are at PwC's EMEA's International Tax, Legal, and Workforce Academy in Prague, Czech Republic, to discuss the latest happenings around Pillar Two. Doug and Calum examine the many practical issues taxpayers, governments and tax advisors are facing to implement the new rules, including disparity in financial accounting, the QDMTT safe harbour, arbitrage arrangements, GloBE reorganization rules, and allocation of deferred taxes.

Labour is calling for Foreign Minister Winston Peters to be sacked as Foreign Affairs Minister and say the attack on Bob Carr is a new low for politicians here. Labour's foreign affairs spokesperson David Parker spoke to Corin Dann.

The Former Prime Minister Helen Clark is among critics who've been sounding the alarm about AUKUS for weeks. Clark spoke to Corin Dann.

On today's episode, Foreign Minister Winston Peters and former Prime Minister Helen Clark join us to discuss whether New Zealand should join Pillar Two of AUKUS, economists warn that unemployment could reach five percent, we're joined by Alan McDonald from the Employers and Manufacturers Association and Craig Renny from the Council of Trades Union.

RNZ has edited this audio to remove comments made by foreign minister Winston Peters regarding former Australian foreign minister Bob Carr. The Foreign Affairs Minister is taking on opponents of New Zealand's possible involvement with the second pillar of the AUKUS military pact. Winston Peters spoke to Corin Dann.

Doug McHoney (PwC's US International Tax Services Global Leader) is with Anthony Sciarra, a Principal in PwC's Tax Reporting and Strategy Practice and the Global Pillar Two Data Strategy leader, to discuss the importance of a Pillar Two Data Strategy. Doug and Anthony detail what taxpayers should be doing today to stay ahead of Pillar Two's complexity, specifically highlighting: data sourcing, data forecasting, qualifying for the CbC Transitional Safe Harbor, considerations for both an insourcing & outsourcing model, existing technology solutions, and the importance of a centralized rules calculation. 

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.

The SEC's final climate rule may be the headline news; however, companies shouldn't lose sight of other requirements impacting first quarter reporting. As we kick off a new year, use our “cheat sheet” summary to keep track of new accounting guidance effective in 2024. In addition, Pillar Two tax legislation is now effective in several jurisdictions around the world and we discuss the implications. Marking a significant milestone in sustainability reporting, the SEC voted on March 6 to finalize its long-awaited climate disclosure rules. In regulatory developments we provide details and the resources you need to get up to speed on the final requirements. The SEC's rule is just one of the sustainability reporting requirements that may impact you. This quarter we launched the first chapter of our new global Sustainability Reporting Guidance – use it as a one-stop shop for guidance on the major required sustainability reporting frameworks around the globe. After issuing three significant new standards in the fourth quarter of 2023, the FASB continues to make progress on the remaining projects on its technical agenda. We provide a preview of what to expect in standard setting in 2024. In this edition of The quarter close, we highlight these and other relevant accounting and reporting topics you should consider as you close out the first quarter of 2024. Transcripts available upon request for individuals who may need a disability-related accommodation. Please send requests to us_podcast@pwc.com.

Doug McHoney (PwC's International Tax Services Global Leader) is at PwC's International Tax Conference in Dana Point, California with former House Ways & Means Chairman Dave Camp, now senior policy advisor in PwC's Washington National Tax Services. Doug and Chairman Camp discuss his political career, drivers behind US tax policy, how Congress negotiates tax legislation, the expiring provisions in the Tax Cuts & Jobs Act (TCJA), the prospects of Congress implementing Pillar Two in the years ahead, and how companies can get involved in the tax legislative process.

On this episode, Doug McHoney (PwC's International Tax Services Global Leader) is joined by Wade Sutton. Wade is PwC's Washington National Tax Service's ITS Leader, a former adjunct professor of international tax at Georgetown University's Law Center, and former Deputy International Tax Counsel, US Treasury. Doug and Wade discuss what drove them to international tax as a career (spoiler: job security) before diving into recent US tax guidance. They discuss the recent foreign tax credit (FTC), corporate alternative minimum tax (CAMT) and Previously taxed E&P (PTEP) notices. They also discuss the interaction of Pillar Two with the FTC rules, dual consolidated loss (DCL) rules, and CAMT. Doug and Wade wrap up by looking ahead to guidance we might see in 2024. 

In this podcast episode, Doug McHoney, PwC's International Tax Services Global Leader, interviews Heather Horn, PwC's Assurance National Thought Leader and host of the twice-weekly PwC Accounting Podcast. Doug and Heather discuss sustainability reporting and its increasing importance in the business world. They cover various regulations and standards, such as the EU's Corporate Sustainability Reporting Directive (CSRD), and the potential intersection between sustainability reporting and tax transparency. Doug and Heather note the similarities between CSRD and other recent reporting requirements, like Pillar Two and the EU's Foreign Subsidies Regulation (FSR). They also highlight the challenges and considerations for companies as they deal with new stakeholders and navigate the new reporting requirements. 

In this TP Talks episode, Kristina Novak (Principal in PwC's US National Tax Services Transfer Pricing practice), Jennifer George (Principal in PwC's US Workforce Transformation practice), and Matt Haag (Principal in PwC's US Transfer Pricing practice), discuss complexities of stock-based compensation (SBC). They start with a broad overview of SBC, the typical fact pattern, and the different lenses of transfer pricing, tax, financial accounting through which SBC issues arise. Next, they provide examples of differences in treatment of SBC in different countries from both a tax and accounting perspective and why one size does not fit all for multinationals looking to synthesize their approach. They also discuss considerations  when analyzing whether to put a recharge agreement in place.  They finish with a discussion of  the interplay between recharge agreements and Pillar Two and final takeaways.Support the show

This week, we begin a collaboration with another popular PwC podcast. Host Heather Horn is joined by Doug McHoney, PwC International Tax Services Global Leader and host of the “Cross-border Tax Talks” podcast. Doug shares insights on the revolutionary new global tax system — the Organisation for Economic Cooperation and Development (OECD) Pillar Two framework — and its impact on companies worldwide.The objective of Pillar Two is for large multinational enterprises to pay a minimum level of tax (a threshold effective tax rate of 15%) on the income arising in each jurisdiction where they operate. Doug joins us to shed light on the judgments involved and what companies can do to prepare.In this episode, you will hear:3:15 - A refresher on Pillar Two, the first global tax system for multinational companies, including:4:30 - A breakdown of the four operating rules prescribed by the framework and the breadth of impact on companies worldwide11:00 - An overview of enactment timing and the three-year transitional safe harbor provisions13:35 - A discussion of the intersection between Pillar Two and US tax policy, including the impact on US companies18:09 - A comparison of the mechanics of Pillar Two and current practice, including an overview of key tax adjustments28:50 - Practical considerations, including materiality considerations, for companies preparing to comply with Pillar Two36:15 - Data and controls implications as companies revamp tax policies and procedures41:50 - Final advice for companies looking to achieve operational readiness for Pillar TwoFor more on OECD's Pillar Two, read our publication, Global taxation: More than an idea - what it means for you now, as well as our prior podcast, Tax policy update - OECD and domestic minimum taxes. Additionally, check out PwC International Tax Services' “Cross-border Tax Talks” podcast, and follow both podcasts on your favorite podcast app for upcoming episodes.Doug McHoney is PwC's Global International Tax Services Leader, helping clients worldwide understand a wide range of global and local tax policy developments and providing technology-enabled consulting services. Doug also hosts the Cross-border Tax Talks podcast series, providing listeners with the latest trends in taxation.Heather Horn is PwC's National Office thought leader, responsible for developing our communications strategy and conveying firm positions on accounting and financial reporting matters. She is the engaging host of PwC's accounting and reporting weekly podcast and quarterly webcast series. With over 30 years of experience, Heather's accounting and auditing expertise includes financial instruments and rate-regulated accounting.Transcripts available upon request for individuals who may need a disability-related accommodation. Please send requests to us_podcast@pwc.com. 

Doug McHoney (PwC's International Tax Services Global Leader) is joined by Steve Kohart for our first podcast in PwC's New York studio. Steve is a PwC international tax partner based in New York, and a former adviser for the OECD Center for Tax Policy and Administration. Doug and Steve discuss the OECD's latest Pillar Two Administrative Guidance, which was published December 18, 2023 and primarily covers the transitional country by country Safe Harbor. More specifically, Doug and Steve address how jurisdictions will implement the guidance, purchase price accounting adjustments, consistent use of data, hybrid arbitrage arrangements, the allocation of CFC taxes, and whether the OECD will provide additional guidance in 2024.

Doug McHoney (PwC's International Tax Services Global Leader) is at PwC's Tax Leadership Conference in breezy Orlando with Dom Megna, a New York-based tax partner leading PWC's US Tax Reporting and Strategy Practice. Doug and Dom discuss Artificial Intelligence (AI) and its place in tax. They focus on four areas - what is conversational AI, machine learning, deep learning, and generative AI (a subset of deep learning). They also cover some impacts of AI: AI for tax practitioners, how AI will affect people's jobs, data opportunities and architecture, Pillar Two, responsible AI, and the ROI of AI. 

Doug McHoney (PwC's International Tax Services Global Leader) is joined by Matt Ryan at PwC's Global Tax Symposium in Rome. Matt is a London-based international tax partner and PwC UK's Pillar Two Leader. Doug and Matt revisit the UK Pillar Two rules for the third time, but now from an enacted law perspective. While the rules are set to apply from the beginning of 2024, the United Kingdom faces an interesting challenge as one of the early adopters of Pillar Two, with enacted legislation, followed by additional OECD guidance. Doug and Matt discuss the tricky task for UK legislators of ‘painting while the paint still dries' (i.e., enacting legislation while the OECD guidance is still changing) and some of the key differences that need to be addressed as a result of the subsequent OECD guidance, as well as still-expected guidance in 2023 and beyond. Doug and Matt discuss from a practical perspective how UK-parented taxpayers are preparing for what is ahead, including approaches to safe harbors. They then dive into complexities created by the particularities of the UK rules around the safe harbor and other key issues, like partnerships and deferred taxes. Finally, the podcast closes with practical next steps companies operating in the UK should consider ahead of 2024.

#NewZealand: PM-elect Luzon doubts Pillar Two AUKUS & What is to be done?  Reuben Steff, Waikato University. New Zealand. https://www.msn.com/en-us/news/world/new-zealand-s-likely-next-prime-minister-signals-openness-to-china/ar-AA1i1NT1 1940 New Zealand