On notice: US developments and Moore hype
Doug McHoney (PwC’s International Tax Services Global Leader) is at PwC’s Tax Leadership Conference in breezy Orlando with Pat Brown, frequent pod guest and co-leader of PwC’s Washington National Tax Services. They discuss US tax updates, including the status and fate of the Tax Cuts and Jobs Act (TCJA); the future of Section 163(j); notices and guidance from Treasury, including the recent Section 174 notice 2023-63; FTC relief notice, and what to anticipate in the coming months and years with respect to foreign tax creditability; what’s included and what’s not included under the corporate alternative minimum tax (CAMT); Section 367(b) ‘Killer B’ regulations; and the Moore case.
Timestamps:
- 1:00 - Pat’s exercise routine
- 4:20 - There is a potential year-end tax bill that remains to be negotiated. What are some of the big issues for both US based and foreign parented groups that invest in the US?
- 9:20 - Why were benefits like R&D expensing or the bonus depreciation parts of the TCJA not permanent if the government wants to encourage foreign investment?
- 15:50 - We’ve received a whole bunch of notices and guidance from Treasury over the last year. Let’s go over some of them.
- 16:10 - Notice 2023-63: Guidance on application of Section 174
- 22:25 - Notice 2023-55: Temporary relief for the foreign tax credit under Sections 901 and 903
- 29:50 - What else should listeners be anticipating with respect to creditability of qualified domestic minimum taxes and FTCs?
- 32:55 - Notice 2023-64: Additional interim guidance on new corporate alternative minimum tax (CAMT)
- 39:00 - Proposed regulations to 367(b) ‘Killer B’ regulations
- 41:35 - The Supreme Court will hear oral arguments on the Moore case in December. Where might this case be going?
- 44:04 - The list of expected and potential upcoming guidance includes: previously taxed E&P (PTEP), Section 987, dual consolidated losses, cloud computing, and Pillar Two.
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