Cross-border Tax Talks Podcast | ONE BIG BEAUTIFUL PODCAST, PART 3: RETURN OF THE G7 | Pat Brown

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 US Treasury’s Associate International Tax Counsel. 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 expensing and Section 163(j); the Senate’s redesign of GILTI, FDII and BEAT; Inflation Reduction Act rollbacks; Treasury’s last-minute removal of Section 899; and the G7’s surprise accord intended to exempt US-parented groups from Pillar Two’s IIR and UTPR while elevating QDMTTs and compliance simplification. They map the procedural and legislative steps still needed, potential timing gaps, and why multinational groups must keep Pillar Two compliance front-of-mind.

Timestamps and Descriptions

00:10 - Welcome and guest introduction; ‘One Big Beautiful Bill’ trilogy setup
02:05 - C-suite takeaway - OB3 delivers ‘permanent’ certainty and ends sunset drama
05:14 - Inflation Reduction Act incentives curbed; orphans saved; Section 163(j) overhaul
10:30 - International focus: Senate rewrites GILTI, FDII and nudges BEAT rate
12:50 - GILTI makeover - expense-apportionment relief, higher rate, 90% FTC limit, QBAI pulled
19:05 - FDII 2.0: no QBAI haircut, interest/R&D not allocated, benefit made permanent
22:15 - BEAT update: structural status quo with rate lifted to 10.5 %
23:00 - What was not in the final Act: Section 899 pulled; surprise sets stage for G7 deal
27:00 - G7’s four principles: IIR/UTPR carve-out, level-playing-field pledge, simplification, credits
36:30 - What’s next? Path to Inclusive-Framework guidance and national legislation—timing risks
40:40 - Compliance realities: QDMTTs persist; US vs non-US MNC exposure
46:00 - Provision challenges, potential Section 899 revival, and closing takeaways