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One Big Beautiful Podcast, Part 5: Outbound Edition

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Manage episode 504446868 series 2395250
Content provided by PwC. All podcast content including episodes, graphics, and podcast descriptions are uploaded and provided directly by PwC or their podcast platform partner. If you believe someone is using your copyrighted work without your permission, you can follow the process outlined here https://podcastplayer.com/legal.

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-apportionment relief; GILTI’s rebrand to Net CFC tested income with a 14% effective rate and ‘directly allocable’ expense questions; inventory-sourcing relief; repeal of the Section 898 one-month deferral; permanent CFC look-through; the Section 958(b)(4) fix; a new Section 951(a)(2)(B) framework; selected technical corrections; and why granular modeling matters now more than ever.

  continue reading

192 episodes

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Manage episode 504446868 series 2395250
Content provided by PwC. All podcast content including episodes, graphics, and podcast descriptions are uploaded and provided directly by PwC or their podcast platform partner. If you believe someone is using your copyrighted work without your permission, you can follow the process outlined here https://podcastplayer.com/legal.

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-apportionment relief; GILTI’s rebrand to Net CFC tested income with a 14% effective rate and ‘directly allocable’ expense questions; inventory-sourcing relief; repeal of the Section 898 one-month deferral; permanent CFC look-through; the Section 958(b)(4) fix; a new Section 951(a)(2)(B) framework; selected technical corrections; and why granular modeling matters now more than ever.

  continue reading

192 episodes

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