Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Beth Bell, a Principal in PwC’s Washington National Tax Services Policy Office. She previously served as a Senior Advisor to the US Treasury Department, Tax Counsel for the US House Committee on Ways and Means, and Policy Director and Tax Counsel in the United States Senate. Doug and Beth discuss the OECD’s January 2026 side‑by‑side package: why consensus formed, how the side‑by‑side and UPE safe harbors operate, and w...

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Hanan Abboud, a Dubai‑based International Tax and M&A partner who leads PwC’s Pillar Two efforts across the Middle East. Doug and Hanan discuss the Cooperation Council for the Arab States of the Gulf (GCC) region’s corporate tax landscape, including country differences, Zakat as a covered tax, and the prevalence of withholding and treaty networks. They then map Middle East Pillar Two adoption: Bahrain’s QDMTT, Kuwa...

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Beth Bell, a principal in PwC’s Washington National Tax Services Policy group. Beth previously served as a senior advisor at the U.S. Treasury Department, tax counsel for the House Ways and Means Committee, and policy director and tax counsel in the U.S. Senate. Doug and Beth discuss contrasts between Senate personal offices and House committee roles; Ways and Means’ tax jurisdiction; and Beth’s experience moving from ...

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by returning guest Tadd Fowler, Senior Vice President, Treasurer, and Global Taxes at the Procter & Gamble company. Doug and Tadd discuss US tax policy after the Tax Cuts and Jobs Act, the OB3 package’s priorities and fixes (including interest expense apportionment, GILTI and FDII changes, and maintaining competitiveness), and why certainty still depends on ongoing policymaker education. They examine the OECD Pillar T...

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Matt Ryan, PwC UK’s International Tax and Treasury Network Leader and the UK’s Pillar Two lead. Recording in Barcelona at PwC’s Global Tax Symposium, they take stock of Pillar Two implementation and the much‑watched ‘side‑by‑side’ agreement. Doug and Matt discuss policymakers’ evolving openness to net CFC tested income (NCTI) coexistence, the UK’s 2027 legislative path with potential effect from 2026, the UTPR safe har...

Wade Sutton (PwC’s WNTS International Tax Services Leader) guest hosts the podcast and is joined by Rob Ozmun, a State and Local Tax Partner, and Monic Kechik, PwC’s WNTS Federal Tax Services Leader. Together they discuss the OB3 ‘curveballs’ to the federal changes: Section 163(j) - ATI addbacks of depreciation and amortization; Section 174A - domestic expensing; Section 168(k) - the return to 100% bonus depreciation; and Section 168(n) - qualified production property (QPP). They explore how ...

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Will Morris, PwC’s Global Tax Policy Leader, from PwC’s Global Transfer Pricing, Customs, and Indirect Tax Conference in Prague. Doug and Will discuss how trade policy now shapes tax outcomes, the G7 ‘side‑by‑side’ debate for Pillar Two, and why geopolitics complicates an Inclusive Framework deal. They explore the EU’s ‘simplification’ agenda (FTT/DEBRA/Unshell pullbacks), overlapping anti‑abuse regimes post-Pillar Two...

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Chris Desmond, a Principal in PwC’s Customs & Trade Practice. Chris leads PwC US’s Global Trade Services. Doug and Chris, while at PwC’s Global Transfer Pricing, Customs, and Indirect Tax Conference in Prague, discuss the Supreme Court’s expedited review of IEEPA‑based tariffs, possible outcomes, and the implications of an estimated ~$108B refund exposure across multiple industries (See our PwC Insight: IEEPA Tarri...

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Pieter Dere, a partner in PwC Belgium’s International Tax Services practice who leads Belgium’s Pillar Two initiative and co‑hosts the Tax Bites Podcast. Doug and Pieter recorded in Prague at PwC’s Global Transfer Pricing, Customs, and Indirect Tax Conference. They discuss Belgium’s Pillar Two compliance landscape: 2024 applicability of QDMTT/IIR/UTPR, a late‑November 2025 filing cycle; the new e‑platform and XML‑only ...

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Sarah Hickey, a PwC Australia International Tax Partner and the Australian tax desk leader in New York City. Doug and Sarah discuss Australia’s corporate tax landscape (30% headline rate; new thin-cap at 30% of tax EBITDA with a retrospective integrity rule on related‑party debt), investment incentives, the two‑speed CFC regime and “use it or lose it” foreign tax credits, and dividend, interest, and royalty withholding...

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Mitch Schuckman, who is retiring after 39 years at PwC and has held a range of leadership roles, most recently leading PwC’s Global Tax Pursuits. Mitch is also the author of “I’ll Tell You a Great Story” and is a certified professional coach. Doug and Mitch discuss the evolving nature of tax careers, from early technical work to client pursuits and leadership development. The conversation explores the importance of sto...

Wade Sutton (PwC’s Washington National Tax Services - International Tax Services Leader) is joined by Pat Brown, an ITS Partner and Co-Leader of PwC’s Washington National Tax Services practice. Pat previously served as the US Treasury’s Associate International Tax Counsel and has been a frequent guest on the podcast. Wade and Pat take a deeper dive into the future of Pillar Two, focusing on the G7’s ‘side-by-side' agreement. They highlight the historical positions of previous US adminis...

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Wade Sutton, a principal who leads the international tax team in PwC’s Washington National Tax Services practice. Doug and Wade discuss OB-3’s outbound impacts and the ripple effects across the system: CAMT interactions and credit ordering; Section 174 R&E expensing elections; Section 163(j) excluding CFC items and the financing/on-lending response; FDII’s shift to FDDEI, a permanent 14% rate, and 2026 expense-appo...

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Nita Asher, an international tax principal in PwC’s Washington National Tax Services practice focused on inbound multinationals, with prior government experience during the TCJA. Doug and Nita discuss the One Big Beautiful Bill Act (“OB3”) and its impact on inbounds, including permanent 100% bonus depreciation; new Section 168N for qualified production property; Section 163(j)’s EBITDA-based ATI; the reworked ‘FDDEI’ (...

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Raza Janjua, a Director in PwC’s ITS practice in New York and author of a recent article on Pillar Two hybrid arbitrage arrangements. Doug and Raza discuss the BEPS Action 2 origins and ATAD 2 implementation; how Pillar Two’s simplified safe harbors spawned detailed hybrid arbitrage rules; the core categories—deduction–non‑inclusion, duplicate loss, and duplicate tax recognition; real‑world traps like preferred equity ...

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by returning guest Craig Stronberg, Senior Director of PwC Intelligence. Craig previously had a near 20-year career in National security affairs before joining PwC. Craig and Doug discuss changes to US global policy and protectionism; the rise of new global powers and alliances; the growing divide between developed and developing countries regarding global tax policy; the debate over globalization’s benefits; and the curr...

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Mike Urse and Calum Dewar, both retiring PwC International Tax partners with decades-long careers in cross-border tax. Mike served as PwC’s US ITS Leader, while Calum built his career across PwC UK and PwC US, specializing in European and global tax systems. Doug, Calum and Mike discuss the dynamic nature of international tax and the intellectual curiosity that drew them to the profession. They also reflect on the evol...

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Pat Brown, an international tax partner and Co-Leader of PwC’s Washington National Tax Services practice and former Deputy Assistant Secretary for Tax Policy at the US Treasury. In part three of Doug’s three-part OBBBA discussion with Pat, they discuss the newly enacted OB3 reconciliation law, focusing on its permanent corporate and individual tax provisions, the recalibration of bonus depreciation, Section 174 expensi...

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Jesse Kavanaugh, an international tax partner at PwC Hong Kong who leads Tax Reporting & Strategy and co-heads PwC’s Asia-Pacific Pillar Two team. Formerly the global head of tax operations for a US tech multinational, Jesse brings both in-house and advisory insights. Doug and Jesse discuss the uneven rollout of Pillar Two across nine Asia-Pac jurisdictions; China, India and US uncertainties; Hong Kong’s Pillar Two...

Doug McHoney (PwC’s International Tax Services Global Leader) is joined on June 24, 2025, by Pat Brown, an International Tax Partner and Co-Leader of PwC’s Washington National Tax Services practice. Pat previously served as the US Treasury’s Deputy International Tax Counsel and has been a frequent guest on the podcast. Doug and Pat start where they left off discussing 'One Big Beautiful Bill' (OB3), in wake of the US Senate Finance Committee Chairman's Substitute Amendment. They discuss the n...