Withholding retaliation? US Sections 891 and 899
Doug McHoney and Tom Patten have a timely discussion on Sections 891 and 899, two lesser-known but increasingly important provisions in the international tax landscape.
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Ep. 113: Tax Policy in Transition: From D.C. to the OECD — What to expect in 2025
A discussion of US tax policy shifts, IRS leadership, how the US engages in OECD tax negotiations, and what the future may hold for transfer pricing.
Brazil Tax Update: Full inclusion to full immersion
Doug McHoney is joined by Dr. Romero Tavares, PwC Brazil’s International Tax Leader and a professor of international tax law in São Paulo.
The Great Economic Reordering: What’s Next for Global Markets?
Doug and Alexis discuss the intersection of global macroeconomics, geopolitics, and international tax policy in a shifting global landscape.
Tariff Tango: What’s next for global business?
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.
US Tax Policy: What’s Staying, What’s Going, and What’s Next?
Doug McHoney and Pat Brown unpack the state of US corporate tax policy in 2025, analyzing how regulatory, legislative, and geopolitical forces could shape the next era of taxation.
Pillar Two: Administrative Guidance Part 5
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.
Ep. 112: Special Edition – Financial Transactions Transfer Pricing
This TP Talks Special Edition podcast explores Islamic financing and its intersection with transfer pricing.
Finally final: The US Section 987 FX regs
Doug McHoney and Rebecca Lee discuss the long-awaited final and proposed regulations under Section 987, which deal with foreign currency gain or loss for qualified business units (QBUs).
From Pillar Two to Transparency: A Tax Executive’s Perspective
With nearly two decades at P&G, Tadd Fowler shares insights with Doug McHoney from his dual leadership in tax and treasury.
US Update: the long-awaited PTEP regs
Doug McHoney and Laura Williams discuss the long awaited previously taxed earnings and profits (PTEP) proposed regulations.
Global tax policy: searching for stability and certainty
Doug McHoney and Will Morris look ahead to potential global tax policy changes.
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