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
The Global Tax Journey: 2025 to 2026
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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 global tax policy. On US policy, they also unpack how OBBBA yielded greater stability; CAMT corrections; stock buyback excise tax guidance; and long-awaited Section 987 rules. Looking ahead to 2026, they assess the potential for additional US tax legislation under reconciliation, as well as the future of Pillar Two, its complexity, and how QDMTTs are now the backbone of Pillar Two.