Cross-border Tax Talks

October 04, 2023

Trick or treat(y): An update on US treaties

Doug McHoney (PwC’s International Tax Services Global Leader) is back in Westminster Studios in St. Louis, Missouri with Nils Cousin, a Washington, D.C. based International Tax Services Principal specializing in US inbound taxation. Together they discuss tax treaties, mutual agreement procedures, the concept of competent authority, the treaty process in the US, recent US tax treaty activities, treaty shopping, the USMCA Trade Agreement, and the future of tax treaties in the United States. Among the treaties and agreements discussed are US treaties and agreements with Chile, Croatia, Hungary, Taiwan, and Russia.

Timestamps:

  • 1:45 - How has Nils’ mathematics degree helped in the world of tax, and how did he get from math, to law, to tax?
  • 4:00 - What is the purpose of tax treaties and what role do they play in international taxation?
  • 5:45 - What does the term ‘competent authority’ mean in the context of tax treaties?
  • 6:50 - What does ‘limitation on benefits’ mean?
  • 10:10 - How do treaties actually assist taxpayers avoid double taxation?
  • 11:55 - What is the process to get a treaty enacted in the United States?
  • 15:30 - What are some of the recent updates regarding US tax treaties?
    • 15:35 - US-Chile Treaty
    • 19:40 - US-Croatia Treaty
    • 24:55 - US-Hungary Treaty
    • 29:20 - US-Taiwan Tax Agreement
    • 32:05 - US-Russia Treaty
    • 36:45 - US-Mexico-Canada Trade Agreement
  • 42:30 - Do you have a near term prediction regarding US tax treaties?

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Speakers

Doug McHoney

International Tax Services Global Leader, PwC US

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Nils Cousin

Director, PwC's International Tax Services Practice, Washington, PwC US

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Doug McHoney

Doug McHoney

International Tax Services Global Leader, PwC US

Geoff Jacobi

Geoff Jacobi

ITS, Knowledge Management Managing Director, PwC US

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