Cross-border Tax Talks

The UK and the US recently have undertaken corporate tax reform and now are experiencing its impacts. Doug McHoney (PwC's International Tax Services Leader) and Neil Edwards (ITS partner on secondment from PwC London) compare and contrast aspects of tax reform between the two jurisdictions leading the charge. Doug and Neil discuss how both countries have attempted to move from a worldwide to a territorial tax system. They also cover the countries' anti-hybrid rules; how the UK's diverted profits tax compares to the US GILTI regime, and whether BEAT is more than an alternative minimum tax regime. In addition, they recognize how the US and UK have, in some cases, gone beyond the OECD's original intent. They cover all of this without mentioning the word 'Brexit'!