Cross-border Tax Talks

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.

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.

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.

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.

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.