Wade Sutton (PwC’s Washington National Tax Services - International Tax Services Leader) is joined by Pat Brown, an ITS Partner and Co-Leader of PwC’s Washington National Tax Services practice. Pat previously served as the US Treasury’s Associate International Tax Counsel and has been a frequent guest on the podcast. Wade and Pat take a deeper dive into the future of Pillar Two, focusing on the G7’s ‘side-by-side' agreement.  They highlight the historical positions of previous US administrations, why  proposed Section 899  was dropped from OBBBA, US dissatisfaction with the lack of accommodations for the US GILTI regime and R&D tax credits, the OECD process and how countries could implement changes, and the potential for simplification including a potential permanent safe harbor. Finally, they look to the future and what may happen next. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Wade Sutton, a principal who leads the international tax team in PwC’s Washington National Tax Services practice. Doug and Wade discuss OB-3’s outbound impacts and the ripple effects across the system: CAMT interactions and credit ordering; Section 174 R&E expensing elections; Section 163(j) excluding CFC items and the financing/on-lending response; FDII’s shift to FDDEI, a permanent 14% rate, and 2026 expense-apportionment relief; GILTI’s rebrand to Net CFC tested income with a 14% effective rate and ‘directly allocable’ expense questions; inventory-sourcing relief; repeal of the Section 898 one-month deferral; permanent CFC look-through; the Section 958(b)(4) fix; a new Section 951(a)(2)(B) framework; selected technical corrections; and why granular modeling matters now more than ever.  

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Nita Asher, an international tax principal in PwC’s Washington National Tax Services practice focused on inbound multinationals, with prior government experience during the TCJA. Doug and Nita discuss the One Big Beautiful Bill Act (“OB3”) and its impact on inbounds, including permanent 100% bonus depreciation; new Section 168N for qualified production property; Section 163(j)’s EBITDA-based ATI; the reworked ‘FDDEI’ (formerly FDII) and its 14% rate with outbound IP limits; shifting IRA credit timelines and ‘foreign entity of concern’ issues; BEAT’s modest rate bump to 10.5% and unchanged credit treatment; the potential future of Section 899; and CAMT interactions. Throughout, they emphasize modeling to avoid BEAT/CAMT whipsaws while capturing OBBBA cash-flow benefits.

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Raza Janjua, a Director in PwC’s ITS practice in New York and author of a recent article on Pillar Two hybrid arbitrage arrangements. Doug and Raza discuss the BEPS Action 2 origins and ATAD 2 implementation; how Pillar Two’s simplified safe harbors spawned detailed hybrid arbitrage rules; the core categories—deduction–non‑inclusion, duplicate loss, and duplicate tax recognition; real‑world traps like preferred equity treated as book debt, FX‑driven mismatches, valuation‑allowance hypotheticals, cash pools and back‑to‑backs; narrow dual‑inclusion relief and why it should be jurisdiction‑level; CFC‑regime interactions; retroactivity and early adoption; and what future administrative guidance and the G7 architecture could mean for US rules such as Sections 245A(e), 267A, and the DCL regime.  

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by returning guest Craig Stronberg, Senior Director of PwC Intelligence. Craig previously had a near 20-year career in National security affairs before joining PwC. Craig and Doug discuss changes to US global policy and protectionism; the rise of new global powers and alliances; the growing divide between developed and developing countries regarding global tax policy; the debate over globalization’s benefits; and the current trade environment. They also discuss how multinational companies are responding to uncertainty, deploying corporate risk management, scenario planning, and gaining competitive advantages. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Mike Urse and Calum Dewar, both retiring PwC International Tax partners with decades-long careers in cross-border tax. Mike served as PwC’s US ITS Leader, while Calum built his career across PwC UK and PwC US, specializing in European and global tax systems. Doug, Calum and Mike discuss the dynamic nature of international tax and the intellectual curiosity that drew them to the profession. They also reflect on the evolution of PwC’s international tax practice, consensus-driven leadership, and building high-performing teams. The trio shares stories on mentorship, the impact of technology - from dictaphones to AI - and how global tax reform has shaped the practice. With humor and candor, they offer career advice to current and future tax professionals and celebrate the relationships, challenges, and learning that have defined their time at PwC. 

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 and former US Treasury’s Associate International Tax Counsel. In part three of Doug’s three-part OBBBA discussion with Pat, they discuss the newly enacted OB3 reconciliation law, focusing on its permanent corporate and individual tax provisions, the recalibration of bonus depreciation, Section 174 expensing and Section 163(j); the Senate’s redesign of GILTI, FDII and BEAT; Inflation Reduction Act rollbacks; Treasury’s last-minute removal of Section 899; and the G7’s surprise accord intended to exempt US-parented groups from Pillar Two’s IIR and UTPR while elevating QDMTTs and compliance simplification. They map the procedural and legislative steps still needed, potential timing gaps, and why multinational groups must keep Pillar Two compliance front-of-mind.  

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Jesse Kavanaugh, an international tax partner at PwC Hong Kong who leads Tax Reporting & Strategy and co-heads PwC’s Asia-Pacific Pillar Two team. Formerly the global head of tax operations for a US tech multinational, Jesse brings both in-house and advisory insights. Doug and Jesse discuss the uneven rollout of Pillar Two across nine Asia-Pac jurisdictions; China, India and US uncertainties; Hong Kong’s Pillar Two legislation (pending when this podcast was recorded, but enacted on June 6, 2025) and HKMTT design; why many countries are shelving the UTPR; looming QDMTT deadlines; the critical difference between data-gathering and calculation engines; pitfalls that blow up transitional safe harbors, including management accounts, hybrid loans, interest-free debt and purchase-price accounting; and industry-specific challenges for shipping, airlines and real estate. Jesse closes with a simple message: start compliance prep now…registration and early QDMTT filings wait for no one. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined on June 24, 2025, by Pat Brown, an International Tax Partner and Co-Leader of PwC’s Washington National Tax Services practice. Pat previously served as the US Treasury’s Associate International Tax Counsel and has been a frequent guest on the podcast. Doug and Pat start where they left off discussing 'One Big Beautiful Bill' (OB3), in wake of the US Senate Finance Committee Chairman's Substitute Amendment. They discuss the next steps in the legislative timeline including the impending July 4th deadline, the impact of the Byrd rule, as well as the many changes to both the business and international provisions. They focus on the major changes to Section 899, global intangible low-taxed income (GILTI), foreign derived intangible income (FDII), and the base erosion and anti-abuse tax (BEAT).  

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. Pat previously served as the US Treasury’s Associate International Tax Counsel and has been a frequent guest on the podcast. Doug and Pat discuss the legislative and international tax implications of the 'One Big Beautiful Bill', including its procedural path through US Congress under budget reconciliation, and its implications for both domestic and cross-border taxpayers. They explore the bill’s temporary business provisions, including TCJA 'orphan' fixes, and the evolving treatment of research expenses, bonus depreciation, and interest deductions. A major focus is Section 899—dubbed the 'super BEAT'—which targets foreign digital services taxes (DSTs), diverted profits taxes (DPTs), and Pillar Two’s undertaxed profits rule (UTPR) with steep retaliatory measures. They also analyze the international negotiations around UTPR exemptions, the impact on treaty obligations, and the ongoing debate over treatment of US tax credits—particularly the R&D credit—under global minimum tax rules. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Jenny Chong, Shanghai-based International Tax Partner and PwC’s Asia-Pacific International Tax Services Leader. Doug and Jenny discuss the structure and enforcement of China’s international tax regime, including corporate tax rates, incentives, CFC rules, and foreign tax credits. They examine the complexities of indirect stock transfer rules, audit trends, and beneficial ownership requirements. The conversation turns to Pillar Two, where Jenny outlines how Chinese multinationals are preparing despite a lack of formal adoption. They also explore the implications of potential termination of the US-China tax treaty and the resurgence of tariffs. Jenny shares how Chinese companies are adapting to compliance burdens and regulatory uncertainty amidst global tax and trade tensions. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Leo Johnson, lecturer at Oxford University’s Smith School of Enterprise and the Environment. Leo is also co-founder of the advisory firm Sustainable Finance, where he chairs the Advisory Council, and previously worked at the World Bank. Known for presenting the BBC series on megatrends and innovation. Leo brings unique insight into organizational behavior, neuroscience, and purposeful leadership. 

Doug and Leo discuss organizational inertia, transformation resistance, and how neuroscience and behavioral science explain our resistance to change—even amid crises like climate change, geopolitical turmoil, and economic stress. They explore how professionals, including those in international tax, can overcome ‘learned helplessness’ and avoid burnout by embracing purpose, agency, and connectedness. Leo introduces the concept of behavioral personas within organizations—catalysts, silent rebels, workhorses, and sustaining innovators—and emphasizes the need for authentic engagement and collaboration to drive meaningful change. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Professor Itai Grinberg, a faculty member at Georgetown University Law Center and a former Deputy Assistant Secretary at the US Treasury Department during the Biden administration. In that role, Itai served as the United States' lead negotiator for the global corporate minimum tax initiative. Doug and Itai discuss the behind-the-scenes history of Pillar Two from the US perspective, exploring its policy rationale, global negotiations, and shifting political dynamics. The conversation begins with how Itai’s got his role at Treasury and builds a detailed timeline tracing the Biden administration’s early support for global minimum tax rules through the 2021 G7 agreement and the development of the Under-Taxed Profits Rule (UTPR). They also delve into the impact of the Build Back Better legislation which was not enacted, the rationale behind the US safe harbor under UTPR, international political tensions including Brexit and US-China relations, and the implications of the April 2025 Trump executive order. The episode closes with reflections on the OECD Inclusive Framework’s future and whether multinational enterprises can expect a workable consensus moving forward. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Arne Schnitger, a Berlin-based International Tax Partner at PwC Germany and co-host of the German-language tax podcast “Frisch Serviert.” Arne previously served in the German Ministry of Finance and brings deep insight into both domestic and cross-border policy developments. Doug and Arne discuss Germany’s evolving corporate tax landscape, including potential rate reductions, simplification initiatives, and the implications of recent coalition negotiations. They dive into Germany’s controlled foreign corporation (CFC) regime, explore the mechanics of the constitutional ‘German debt brake,’ and unpack recent developments surrounding Pillar Two. The conversation highlights the intersection of German and US tax policy, the ongoing tension between multilateralism and unilateral measures, and the administrative and technical challenges multinationals face under the global minimum tax framework. They also examine prospects for EU-level simplification and the future of long-standing anti-avoidance measures in light of Pillar Two implementation. 

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 Dr. Alexis Crow, Partner and Chief Economist at PwC US. Before joining PwC, Dr. Crow taught at the London School of Economics. Doug and Alexis discuss the intersection of global macroeconomics, geopolitics, and international tax policy in a shifting global landscape. They break down the impact of the Trump administration’s latest tariffs on Canada and Mexico, inflationary pressures, interest rates, and the fiscal cliff facing the US. 

Doug and Alexis explore how the geopolitical climate is shaping international trade, the potential winners and losers of increased tariffs, and the broader economic implications of Trump 2.0. They also analyze regional macroeconomic trends, from China’s economic resilience and India's manufacturing rise to Europe's fiscal strategies and Latin America’s economic experiments. Lastly, they discuss how businesses—particularly multinationals—should be preparing for upcoming policy shifts and economic disruptions. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Kristin Bohl, a Partner in PwC’s Customs and International Trade Practice. Kristin previously served as a judicial law clerk at the U.S. Court of International Trade. Doug and Kristin discuss the rapidly evolving trade and tariff landscape, focusing on the recent executive orders imposing new tariffs on Canada, Mexico, and China under the ‘America First’ trade policy. They break down the impact of tariffs on industries such as automotive, pharmaceuticals, retail, and technology, and cover strategies that businesses can deploy to mitigate costs. Key topics include the authority of the US President to impose tariffs, the role of trade deficits in tariff policy, and the use of tariffs as a foreign policy tool. They also explore potential retaliatory measures from US trading partners, the impact on global supply chains, and short to long-term strategies for businesses to adapt to the new tariff regime. 

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. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Rebecca Lee, an International Tax Principal in PwC’s Washington National Tax Services practice. Rebecca specializes in financial transactions and digital assets and is one of the most frequent guests on the podcast. Doug and Rebecca discuss the long-awaited final and proposed regulations under Section 987, which deal with foreign currency gain or loss for qualified business units (QBUs). They dive into key topics, including methods for calculating 987 gains and losses, the transition rules, applicability dates, and the implications of different election options. They also cover major changes from the proposed to final regulations, including adjustments to the treatment of Section 988 transactions within a QBU, tax accounting considerations, the controversial suspended loss rules, and how partnerships are impacted.  

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. 

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Laura Williams, an International Tax Principal at PwC’s Washington National Tax Services office. Laura previously worked as the International Branch Chief at the IRS Office of Chief Counsel. Doug and Laura discuss the long awaited previously taxed earnings and profits (PTEP) proposed regulations. Together they walk through the core aspects of the PTEP regime, including PTEP accounting, increases and decreases to basis of stock and other property, foreign currency gain or loss, allocation of foreign tax credits, 'covered distributions’, US consolidated group rules, and the anti-avoidance rule. See our PwC Tax Insight for more details. 

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.