Cross-border Tax Talks

Hosted by PwC

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Episodes

217

Latest episode

Aug 2026

Language

EN-US

About the show

PwC specialists share insights and perspectives on key issues impacting the ever-changing tax landscape. Our podcasts aim to provide quick, easy and up-to-date 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.

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60 recent

August 4, 202626 min

Globalized State Aid: Understanding Europe’s Foreign Subsidies Regulation

Wade Sutton, PwC’s International Tax Leader for the Washington National Tax Services Office, fills in as host while Doug is away on assignment. Wade welcomes Will Morris, PwC’s global tax policy lead and former chair of the AmCham EU Tax Committee. In this episode, Wade and Will discuss the EU Foreign Subsidies Regulation (FSR). They cover its state-aid origins, reach into M&A and public procurement, and early enforcement record. The episode examines the European Commission’s recent assessment, possible reductions in reporting burdens, and the three-step analysis from foreign financial contribution (FFC) to subsidy to market distortion. The conversation also covers tax incentives and credits, Inflation Reduction Act and Pillar Two interactions, data-collection challenges, geopolitical considerations, standstill risks, and practical steps before an EU transaction or procurement bid.

July 23, 202650 min

Portal Combat 2: Pillar Two compliance post-mortem

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Pat Coughlin, a Chicago-based tax director in PwC’s Quantitative Solutions and Technologies Practice within International Tax Services and a former Notre Dame running back. Doug and Pat discuss the June 30, 2026, Pillar Two compliance post-mortem, including PwC’s experience filing more than 50,000 returns with a success rate above 99%. They dive into how business rules and filing capabilities were built across dozens of jurisdictions, what late portals and conflicting validations revealed about the system, why the OECD and local tax authorities should act quickly on timely-filed GIR relief, a longer 2025 filing deadline, clearer amended-return mechanics, and broader simplification. They close with practical advice for 2025: start now, focus on calculations, and narrow review to the sections that matter most.

July 7, 202641 min

Japan Tax Update: Tea, Tariffs and Top-up Taxes

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Shin Yamaguchi, a tax partner at PwC Japan, the Japanese inbound tax leader, and host of the English-language podcast Dial in Japan. Doug and Shin discuss Japan’s current inbound and outbound investment environment, the role of supply-chain diversification and energy security in Japanese outbound strategy, and why Japan remains an active market for inbound acquisitions and carve-outs. They also explore Japan’s Pillar Two implementation timeline, readiness for compliance, the interaction between Pillar Two and Japan’s CFC rules, practical administrative and substantive challenges for Japanese-parented groups, tariff-related uncertainty for US investment, and the tax controversy environment in Japan, including the continued focus on transfer pricing.

June 19, 202637 min

Taiwan Update: Treaties, Tariffs and Top-Up Tax Turbulence

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Paulson Tseng, PwC Taiwan’s International Tax Services and Transfer Pricing Leader, the firm’s Human Capital Leader, and host of the Finance and Tax Cafe podcast.Doug and Paulson discuss Taiwan’s corporate tax framework, including the 20% corporate rate, foreign tax credit limits, withholding tax friction for services, and CFC rules; how inbound investment remains strong in semiconductors and R&D while outbound models are shifting toward more diversified, multi-nodal footprints; Taiwan’s current Pillar Two posture, top-up tax exposure, and readiness challenges around data, education, and compliance; whether Pillar Two is already changing business behavior; tax controversy themes in Taiwan, especially transfer pricing, withholding tax, and risk-based audits; and Paulson’s own podcast and its broader finance, economic, and workplace-stress topics.

June 4, 202634 min

No strait answers: Energy shocks, AI stocks, and trade talks

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Dr. Alexis Crow, partner and Chief Economist for PwC US. Prior to joining PwC, Alexis taught at the London School of Economics. Doug and Alexis discuss the macroeconomic and geopolitical implications of the Iran conflict, including energy-market scarring, oil-price scenarios, fiscal supports, inflation pressures, and central-bank constraints. They also examine the durability of US growth, AI-driven investment, consumer demand, and private credit risk; then move through global trade developments and regional dynamics across Asia-Pacific, Latin America, Europe, and North America. The conversation closes with the “re-industrial era,” energy addition, automation, workforce skills, and financial-stability risks that may be underappreciated.

May 27, 202626 min

Portal Combat: Pillar Two Forms, Deadlines, and the Fight for Certainty

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Will Morris, PwC’s Global Tax Policy Leader, at PwC’s Asia-Pacific Global Tax Symposium in Hong Kong. Will previously chaired the Business and Industry Advisory Committee (BIAC) Tax Committee for 10 years. Doug and Will discuss the acute uncertainty surrounding Pillar Two filing readiness as initial 2024 calendar-year deadlines approach, including the OECD’s May 18, 2026, common understanding document, GIR central filing, local filing portals, XML schema differences, penalty relief, safe harbor elections, QDMTT and top-up tax returns, taxpayer outreach to BIAC, the OECD, and national governments, the OECD implementation toolkit, 52/53-week fiscal-year UTPR guidance, and unresolved dispute resolution questions.

April 29, 202636 min

Mexico tax update: Nearshoring, audits, and treaty twists

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Adriana Rodriguez, a PwC international tax partner based in Mexico City, for a discussion recorded at PwC’s International Tax Conference. Doug and Adriana discuss the core features of Mexico’s corporate tax system, including corporate income tax, withholding taxes, VAT, inflation adjustments, CFC rules, capital gains planning, and the impact of the multilateral instrument on treaty access. They also explore whether Mexico is likely to adopt Pillar Two, how Mexican multinationals are preparing for compliance, the role of incentives in inbound investment, the continued relevance of the maquila regime, rising audit and transfer pricing pressure, expanding tax authority digitization, and practical lessons for multinationals investing in Mexico.

April 15, 202642 min

Tariff Strike Zone: IEEPA Refunds, Audit Pressure, and Fragmented Trade

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Chris Desmond, leader of PwC’s US Global Trade Services practice and, as Doug notes, a ‘reformed transfer pricing partner.’ Doug and Chris discuss the current fragmented trade environment, why tariffs may remain a lasting feature rather than a short cycle, rising customs enforcement, the Supreme Court’s IEEPA decision and the operational complexity of securing refunds, and how companies should assess gross-versus-net refund exposure across suppliers and customers. They also cover why the tariff environment is forcing customs, tax, and transfer pricing teams to work more closely together, how first sale operates and why it remains under scrutiny, and practical steps tax leaders should take on coordination, data, and documentation.

March 30, 202629 min

Lost in FX Translation: The latest 987 regs

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Laura Valestin, an International Tax Services Partner in PwC’s Washington National Tax Services practice, where she focuses on financial transactions. In this episode, recorded at PwC’s International Tax Conference in Carlsbad, Laura unpacks the latest Section 987 developments following Notice 2026-17. Doug and Laura discuss what Section 987 is, why it matters for foreign currency gain or loss in branch and disregarded entity structures, the long regulatory history from the 1991 proposed regulations through the 2024 final rules, the new simplified equity-and-basis-pool method, remittance and loss-suspension mechanics, hedging rules, the proposed CFC election, reliance and applicability dates, and practical taxpayer action items, including comment opportunities and modeling decisions for 2025 and beyond.

March 17, 202643 min

Tariffs, Tensions, and Tightropes: A global risk tour

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Anja Manuel, co-founder and principal at Rice, Hadley, Gates, and Manuel LLC, a strategic consulting firm, and a former diplomat, author, and foreign policy advisor. Doug and Anja discuss the geopolitical forces reshaping cross-border business, including the Iran conflict and its implications for oil, shipping, Gulf investment, and AI infrastructure; China’s internal trajectory, tariffs, critical minerals, Taiwan, and supply-chain strategy; the growth outlook for Southeast Asia and India; Europe’s competitiveness challenges and the war in Ukraine; Venezuela’s political and investment risks; the effect of possible US midterm shifts on foreign policy; and whether international institutions, alliances, and the broader global economy still offer reasons for optimism despite a highly unstable backdrop.

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Cross-border Tax Talks

About the show

Listen to episodes

Globalized State Aid: Understanding Europe’s Foreign Subsidies Regulation

Portal Combat 2: Pillar Two compliance post-mortem

Japan Tax Update: Tea, Tariffs and Top-up Taxes

Taiwan Update: Treaties, Tariffs and Top-Up Tax Turbulence

No strait answers: Energy shocks, AI stocks, and trade talks

Portal Combat: Pillar Two Forms, Deadlines, and the Fight for Certainty

Mexico tax update: Nearshoring, audits, and treaty twists

Tariff Strike Zone: IEEPA Refunds, Audit Pressure, and Fragmented Trade

Lost in FX Translation: The latest 987 regs

Tariffs, Tensions, and Tightropes: A global risk tour

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