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PwC specialists share insights and perspectives on key issues impacting the ever-changing international tax landscape. Our podcasts aim to provide quick, easy and up-to-date international 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 Innovation, by Yushan Ventures, will bring you weekly insight and expert interviews on subjects relevant to our work around the globe. Strong focus will be on corporate and startup innovation as it pertains to doing business across boundaries and borders into Asia Pacific, the EU, and North America. Feel free to follow Yushan on Twitter: www.twitter.com/yushanventures
 
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show series
 
A review of the week's major US international tax-related news. In this edition: US Senate Majority Leader, Sen. Manchin meet again to discuss budget reconciliation – US Supreme Court accepts FBAR case for review – IRS plans to expand transfer pricing audit coverage.
 
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Mike Urse, current International Tax Partner and former US International Tax Services Leader for the 100th episode of the Cross Border Tax Talks podcast. Doug and Mike discuss the changing world of international taxation, focusing on the current status of holding companies, f…
 
A review of the week's major US international tax-related news. In this edition: President Biden expresses confidence budget reconciliation bill will pass Congress; meetings held – Congressional Republicans propose anti-inflationary measures, including tax cuts – Republican House Ways and Means Committee members ask Treasury to delay final foreign …
 
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined in Washington D.C. by Dom Megna, Tax Partner and leader of PwC’s US Tax Reporting and Strategy practice. They discuss the latest on Pillar Two developments, GAAP considerations, Enterprise Resource Planning Systems, the Cloud, the future of data collection, and more.…
 
A review of the week's major US international tax-related news. In this edition: US Sen. Manchin says no deal yet on limited budget reconciliation bill – Treasury Secretary comments on BEPS Pillar One – Treasury official offers insights on computing CFCs’ minimum taxes in BEPS Pillar Two – Treasury Secretary says no delay in final foreign tax credi…
 
A review of the week's major US international tax-related news. In this edition: Congress returns from Memorial Day holiday to budget reconciliation uncertainty – Support Ukraine Through Our Tax Code Act introduced in the House – US government supports excluding reinsurance and asset management from the BEPS 2.0 Pillar One – OECD initiates public c…
 
A review of the week's major US international tax-related news. In this edition: Congressional Democrats move “soft deadline” for BBB action to August recess – US Treasury offers insights to future FTC guidance – OECD officials discuss BEPS 2.0 progress.
 
A review of the week's major US international tax-related news. In this edition: US House leaders hope to pass “China competitiveness” bill before 4 July recess – Senate introduces bill to disallow foreign tax credits (FTCs) for taxes paid to Russia or Belarus – Treasury, IRS considering changes to FTC regulations – IRS proposed Section 1256 regula…
 
A review of the week's major US international tax-related news. In this edition: Little action on budget reconciliation as US Congress focuses on ‘China competitiveness’ legislation – Treasury official reveals government working on “Killer B” cross-border triangular reorg regs, Section 367(d) rules involving transferred IP repatriated to US.…
 
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Pat Brown, PwC’s International Tax Policy Leader, making his sixth appearance on the podcast. Doug and Pat discuss the Biden Administration's fiscal year 2023 budget proposals as explained in the Green Book, how some of the proposals interact with the OECD’s Pillar Two Model …
 
A review of the week's major US international tax-related news. In this edition: US Treasury Secretary calls on Congress to pass BEPS-like minimum corporate tax – Treasury officials comment on BEPS 2.0 – IRS publishes changes to QI withholding agreement rules – IRS unclear on scope of financial transaction transfer pricing regulation project – US H…
 
A review of the week's major US international tax-related news. In this edition: US Congress returns to Washington to budget reconciliation uncertainty; Senator Manchin offers high-level clarity – OECD holds public consultation on Implementation Framework for BEPS 2.0 Pillar Two GloBE Rules – OECD releases public comments on Draft Model Rules for D…
 
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by PwC’s Calum Dewar, Leader of PwC’s Integrated Global Structuring practice. They discuss the Pillar Two Model Rules & Commentary and its potential impacts on the global tax system, transfer pricing adjustments, deals and more.על ידי PwC
 
A review of the week's major US international tax-related news. In this edition: US Congress returns to Washington; Democrats may make one last attempt at reconciliation legislation – Biden Administration supports both BEAT repeal and replacement with UTPR and BBB’s BEAT reforms.
 
A review of the week's major US international tax-related news. In this edition: US Treasury Secretary says BEPS 2.0 will help global economies recover from COVID-19 pandemic, Ukraine crisis – IRS releases new Schedules K-2, K-3 FAQs – US Senate Foreign Relations Committee issues report on proposed US-Chile tax treaty.…
 
A review of the week's major US international tax-related news. In this edition: Prospects for post-Build Back Better Act reconciliation bill uncertain – Senate bill would deny US FTCs for Russian taxes paid – OECD announces public consultation on draft model rules on scope of Amount A in BEPS 2.0 Pillar One.…
 
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by PwC’s Dr. Alexis Crow, PwC’s Geopolitical Investing Practice Leader. They discuss macroeconomic trends, the geopolitical landscape, the inflationary environment, trade wars, global/economic impacts on various sectors,and much more.…
 
A review of the week's major US international tax-related news. In this edition: Biden Administration releases FY2023 budget with international tax proposals – US Senate Foreign Relations Committee approves US-Chile income tax treaty – OECD public consultation on crypto-asset reporting framework expected by end of May.…
 
A review of the week's major US international tax-related news. In this edition: President Biden to release FY 2023 budget on 28 March – Sen. Manchin revives pared-down budget reconciliation talks – Final US FTC regulations will be amended to reflect BEPS 2.0 Pillar One and Pillar Two – Senate Foreign Relations Committee to take up US-Chile tax tre…
 
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by PwC’s Washington National Tax Services International Tax Leader Michael DiFronzo, former Deputy Associate Chief Tax Counsel International at the IRS. They discuss some of the practicalities of the creditability rules in the Final FTC regulations (see February 2022 CBTT episod…
 
A review of the week's major US international tax-related news. In this edition: Congress passes $1.5t Omnibus spending bill with no tax title – OECD releases BEPS 2.0 Pillar Two commentary – US Senate Finance Committee Chairman supports tax sanctions for Russia and Belarus – IRS official recommends all taxpayers seeking PLRs should avail of new fa…
 
A review of the week's major US international tax-related news. In this edition: Congress passes $1.5t Omnibus spending bill with no tax title – Treasury official confirms previously-taxed earnings and profits regulations coming in latter half of 2022 – IRS official says partial US FTC may only be available on foreign withholding on IP royalties in…
 
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by PwC Value Chain Transformation Specialist Tom Quinn. They discuss the Sixth Circuit Court of Appeals ruling to uphold the US Tax Court’s May 5, 2020 decision, and concluded that a CFC’s income ‘attributable to’ a branch, in this case a manufacturing branch, per se is foreign …
 
A review of the week's major US international tax-related news. In this edition: President Biden presents first State of the Union address; lists provisions but does not mention Build Back Better – Sen. Manchin says he could support limited reconciliation package focused on taxes, climate change and deficit reduction – Senate Democrats eye US-Russi…
 
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Puneet Arora, PwC ITS Partner and PwC’s Financial Services Consulting leader. They discuss the latest EU anti-tax avoidance directive (ATAD3), diving into the details and impact it could have on the financial services industry; the importance of modeling for Pillar Two; and t…
 
A review of the week's major US international tax-related news. In this edition: US Senate mulls anti-inflation measures – IRS releases FAQs on transition relief for certain domestic partnerships and S corporations completing new Schedules K-2 and K-3 – Treasury official comments on future proposed regulations on cryptocurrency reporting requiremen…
 
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Wade Sutton, PwC ITS Partner in the Washington National Tax Practice office and former deputy international tax council at Treasury. They discuss the highly technical topics of the final foreign tax credit regulations, credibility of tax under Section 901, the definition of a…
 
A review of the week's major US international tax-related news. In this edition: Sen. Manchin reiterates need for wholly new spending and tax bill; Congress faces full agenda – OECD announces first wave of consultations on the BEPS 2.0 Pillar One rules, releases consultation document – OECD official reinforces BEPS 2.0 timeline.…
 
A review of the week's major US international tax-related news. In this edition: Sen. Manchin confirms Build Back Better discussions back on – Concern over double taxation if US GILITI unamended – Republican tax writers warn BEPS Pillars require congressional action – Treasury releases final regulations on treatment of domestic partnerships under S…
 
A review of the week's major US international tax-related news. In this edition: President Biden favors breaking up Build Back Better into smaller bills – OECD BEPS 2.0 Pillar Two model rules commentary expected in early February – OECD releases 2022 Transfer Pricing Guidelines.
 
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Calum Dewar, PwC ITS Partner and leader of PwC’s Integrated Global Structuring Practice, heading our Outbound, Inbound, and Value Chain Transformation teams. Doug and Calum discuss Pillar Two Model Rules, the OECD/G20’s Inclusive Framework, the EU Directive, and more specific…
 
A review of the week's major US international tax-related news. In this edition: No action on President Biden’s Build Back Better agenda as Congress pivots to other legislative priorities – Treasury developing interim guidance on cryptocurrency reporting.
 
A review of the week's major US international tax-related news. In this edition: Build Back Better Act faces uncertain path – Treasury and IRS release final foreign tax credit regulations – IRS finalizes rules addressing the tax consequences of the elimination of LIBOR and other interbank offered rates.…
 
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined in PwC’s DC studio by Mohamed Kande, PwC Vice-Chair and US and Global Advisory Leader. They discuss the need for proactive and intentional mentorship; relationship building in the virtual environment; the three different types of transformation trending in the market; and how (a…
 
A review of the week's major US international tax-related news. In this edition: Senator Joe Manchin will not support Build Back Better Act; Majority Leader will bring forward ‘modified’ version of bill in new year – OECD releases Model Rules on the Pillar Two Global Minimum Tax.
 
A review of the week's major US international tax-related news. In this edition: US Senate will not take up Build Back America Act in 2021 – Updated Senate Finance Committee's title of the Build Back Better Act retains House’s international tax proposals, but with major technical changes – Final foreign tax credit regulations clear OMB, return for …
 
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Jeff Endress, US Outbound Tax Practice leader. They discuss the House-passed Build Back Better (BBB) bill, delayed effective dates, Section 163(n), foreign tax credits, country-by-country, the complexity of global tax, Pillar Two, uncertainties in the deals market, and the fu…
 
A review of the week's major US international tax-related news. In this edition: US Senate Democratic BBBA meetings with Parliamentarian concluded; bipartisan “Byrd bath” meetings begin next week – Senate Foreign Relations Committee Republicans urge vote on proposed 2010 US-Chile tax treaty – Treasury’s FinCEN published proposed regulations on bene…
 
A review of the week's major US international tax-related news. In this edition: US Congress turns to Build Back Better reconciliation bill after recess – Final foreign tax credit regulations release before year-end -- US, India announce digital tax, trade action compromise – Technical aspects of model rules for OECD BEPS Pillar 2 complete; further…
 
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Ugo Alisiobi, ITS Partner, based in our New York Metro ITS practice, for Ugo’s first time in St. Louis. They discuss their paths to careers in international taxation; the struggles, joys, and rewards of being an international tax practitioner; being proactive and authentic in…
 
A review of the week's major US international tax-related news. In this edition: US, Turkey announce digital tax, trade action compromise – OECD committed to BEPS Pillars in effect by end of 2023 – US Congress in recess; Senate expected to take up House-passed Build Back Better Act after Thanksgiving break.…
 
A review of the week's major US international tax-related news. In this edition: President Biden signs infrastructure legislation – House passes Build Back Better Act budget reconciliation bill, Senate consideration after Thanksgiving holiday – IRS releases new tool to support US withholding agents compliance with reporting, withholding re IRS Form…
 
A review of the week's major US international tax-related news. In this edition: President Biden to sign infrastructure legislation next week with crypto provisions; House Speaker wants reconciliation vote week of 15 November – Final foreign tax credit regulations expected before year-end – Proposed PTEP regulations moving forward.…
 
Doug McHoney (PwC's US International Tax Services Co-Leader) is joined by Rebecca Lee (PwC ITS Washington National Tax Partner), who specializes in cross-border financial transactions. They discuss trends in cryptocurrency, including ‘operation hidden treasure,’ taxation of cryptocurrency transactions, US tax reform, El Salvador’s adoption of Bitco…
 
A review of the week's major US international tax-related news. In this edition: US House poised to pass Build Back Better Act budget reconciliation bill, infrastructure legislation – IRS ILM concludes extended six-year assessment period under Section 6501(e)(1)(c) applies to entire tax liability, not just omitted subpart F and/or GILTI items.…
 
Doug McHoney (PwC's US International Tax Services Co-Leader) is in PwC's brand new studio in Washington, DC with Will Morris (PwC’s Deputy Global Tax Policy Leader). Will also was appointed Chair to the American Chamber of Commerce to the European Union and Chair to the Business Industry Advisory Committee to the OECD. Doug and Will discuss the jou…
 
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