Cross-border Tax Talks
PwC specialists share insights and perspectives on key issues impacting the ever-changing tax landscape. Our podcasts aim to provide quick, easy and up-to-date tax developments to help you stay current and competitive in today's challenging business environment. Listen to episodes at your convenience via your desktop computer or smart device.
Cross-border Tax Talks
No double dipping! US proposes new regulations
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.