Doug McHoney (PwC's US International Tax Services Leader) and Pat Brown (PwC's International Tax Policy Leader) discuss the past, present, and future of US and global corporate taxation in 2020 and beyond. Doug and Pat discuss: issued and pending TCJA regulatory guidance, including anti-hybrid, Section 163(j), Foreign Derived Intangible Income (FDII), Global Intangible Low-Taxed Income (GILTI) high-tax exception, previously-taxed earning and profits (PTEP), and Foreign Tax Credit (FTC) regulations; Treasury's effort to have all TCJA guidance 'done' by October 2020, and what 'done' actually means; the interplay between OIRA, Treasury, and the White House; potential changes to the US corporate tax structure and rate after November's presidential election; the sustainability of the Section 250 deduction; the current state of the EU's Anti-Tax Avoidance Directive II (ATAD II); the global landscape of digital taxation; and continuing developments to the OECD's 'BEPS 2.0' initiative.
