Cross-border Tax Talks

2022 Year in Review

Doug McHoney (PwC's US International Tax Services Global Leader) is joined by Pat Brown, International Tax Partner and co-Leader of the Washington National Tax Practice to look back at the very eventful and tortured 2022 year in international taxation. They cover topics including US Congressional activities, Treasury’s 2022 regulations and guidance, recent international tax and transfer pricing rulings, and the progress made on Pillar One & Two..

Timestamps:

• 2:30 - Why don't we start with a quick recap of what was happening at the end of 2021, particularly with ‘Build Back Better’ and international tax reform?
• 9:50 - What did the 2022 midterm elections mean for US international tax?
• 13:00 - Will Congress pass Pillar Two legislation in the next two years?
• 14:40 - Pat’s thoughts on the termination of the US-Hungary income tax treaty.
• 17:45 - Treasury was very busy promulgating regulations. Any general themes or highlights from a regulatory perspective in 2022?
• 23:20 - It was also a big year for international tax-related court decisions . The Supreme Court denied cert of the Whirlpool case concerning the foreign based company sales regulations. What does this case mean more broadly for tax regulations? What about the transfer pricing cases, e.g., Medtronic.
• 30:15 - The Pillar Two Model Rules and Commentary came out in November 2021. How did these rules advance in 2022?
• 35:15 - What was Congress’ response to the official EU Directive on Pillar Two?
• 38:00 - We got a lot of OECD Pillar One consultation documents in 2022, however, Pillar One did not move forward at the rate of Pillar Two. Where are we today on Pillar One?
• 42:15 - How will countries look for additional revenue in the year ahead?
• 44:30 - What international reforms moved forward in the European Union, e.g., ATAD, the common consolidated tax base, the foreign subsidies regulation?
• 47:15 - What are your predictions/recommendations for the year ahead?

View full podcast series