What Latin America Can Teach About Tariffs, Transfer Pricing

Multinational corporations have been hustling to make sense of the flurry of US tariff policy changes this year, and figure out how to factor that into their transfer pricing. One place that's been in this situation before: Latin America. For decades, companies there have been navigating tariffs and the impacts on their tax planning—including transfer pricing, or how companies value transactions between their related entities. This week on the Talking Tax podcast, Webridge Technology Global Tax Adviser Hernan Katz talks about the lessons companies can take away from the experience of Latin American countries. These include making sure staff across departments are working together to tackle issues of trade and transfer pricing, how tax authorities try to crack down on companies they suspect aren't following the rules, and explaining how intercompany dealings are motivated by business reasons—not tax or trade. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The fate of the OECD-led global tax deal was rocked this week after the US and its Group of Seven allies came to an understanding that would exempt American companies from two key parts of the global minimum tax framework. G7 countries agreed to the exemption over the weekend in exchange for Congress removing Section 899 from its tax-and-spending bill—a provision referred to as the "revenge tax" that would have hiked taxes on foreign-owned companies if their home countries imposed "unfair" taxes on US businesses. In this week's episode of Talking Tax, reporter Lauren Vella talks about how the agreement was reached, and why the G7's statement is only the first small step toward the US achieving what it calls "side-by-side" treatment of its tax system and the global minimum tax framework. She also discusses Canada's decision to revoke its digital services tax to bring President Donald Trump back to the trade negotiating table, and what impact it could have on other countries that have similar levies in place. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Congress is reconsidering the accounting guardrails it put in place more than two decades ago to ensure investors can trust the revenues and asset values listed companies publish. Republican budget proposals would abolish the US audit regulator and reassign its work to the Securities and Exchange Commission. While lawmakers negotiate over what will end up in a final version of their tax and spending bill, the proposals have prompted debate over how best to regulate auditors and the role of the Public Company Accounting Oversight Board. A member of the board and two former executives turned whistleblowers of once-corporate titans Enron Corp. and WorldCom Inc. spoke with Bloomberg Tax reporter Amanda Iacone about whether the audit regulator should remain independent or whether it would benefit from being folded into the federal government. On this episode of Talking Tax, Sherron Watkins, a former Enron finance executive, and Cynthia Cooper, a former WorldCom chief audit executive, argue that Congress shouldn’t scrap an agency that oversees auditors that act as investors’ last line of defense. To Christina Ho, a current PCAOB member who has objected to the board’s approach, moving auditor oversight to the SEC would counter what she sees as regulatory overreach and provide new opportunities to improve audit quality. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The Republican-led Senate Finance Committee unveiled its portion of the mammoth tax-and-spending legislation that's quickly moving through Congress, and there's a lot to unpack. The Senate bill has dozens of differences from the House version. It makes several business breaks permanent, softens the excise tax on university endowments, and phases out more slowly cuts to clean energy credits, while smoothing edges on the so-called "revenge tax." But there are many similarities in the approaches the two bills take—both have tax breaks on income such as tips and overtime sought by President Donald Trump, and seek to extend much of the 2017 GOP tax law. Things are moving quickly as the Senate aims to pass its version out of its chamber before the July 4 break. In this week's episode of Talking Tax, Bloomberg Tax reporter Chris Cioffi speaks with host David Schultz on what's in the bill, what's left out, and where Congress goes from here. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Recent layoff announcements at Big Four accounting, tax, and consulting firms come as the industry faces economic uncertainty and a shrinking talent pool. The accounting profession is at a crossroads as a new class of students graduate. While recent data shows heightened interest in both undergraduate and master's degree programs, the industry faces possible disruptions like workforce reductions and emerging artificial intelligence tools. Deloitte LLP announced in April it would lay off government consulting employees as the Trump administration slashed federal contracts. The firm said in a statement the personnel actions were based on its public-sector clients' "evolving needs," among other factors. PwC LLP plans to cut roughly 1,500 jobs, many in its tax and assurance practices, the firm said last month, after two years of historically low levels of turnover. The firm plans to slow down its campus recruiting and will offer fewer internships for next year. But PwC announced this week it plans to reorganize its US advisory business, doubling the number of divisions from four to eight. The move "is being approached from a position of strength," according to a statement from PwC US advisory leader Tyson Cornell. Peter Demerjian is the director of the school of accountancy at Georgia State University. Namaan Mian is the chief operating officer at Management Consulted, a professional training and coaching organization. Demerjian and Mian spoke with Bloomberg Tax reporter Jorja Siemons about the recent layoffs, the industry's embrace of AI, and potential impacts on the industry's next generation. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The “revenge” tax provision that’s in the giant tax bill working its way through Congress has a lot of people worried. Known as Section 899, the provision would impose stiff, retaliatory tax rates on companies and people from countries that the US deems to be imposing "unfair" and "discriminatory" taxes against US companies. It was included in the version of the bill House Republicans narrowly passed last month, and now gets Senate attention. The aim of Section 899 is to push those countries into changing their policies, but many observers fear the move would lead to lower foreign investment in the US, costing American jobs and cutting into economic growth. That’s not the only reason for concern. Financial markets are worried about the retaliatory tax’s potential impact on the value of US assets. Some observers think Section 899 would damage the US’s longstanding reputation as a stable, reliable place for global companies to do business and for global investors to put their money, On this episode of Talking Tax, Bloomberg Tax senior reporter Michael Rapoport explains the retaliatory-tax proposal and discusses its prospects for becoming law. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

Companies scored wins after the House passed a multi-trillion-dollar tax bill that largely preserved the current tax rates on foreign-earned income. Republicans' 2017 Tax Cuts and Jobs Act created a new international tax regime including a minimum tax on global intangible low-taxed income, or GILTI, a reduced tax rate on foreign-derived intangible income, or FDII, and a base erosion and anti-abuse tax, or BEAT. Each of these tax rates will go up in 2026 without congressional action, but House lawmakers made slight changes that will result in minimal tax increases. But the debate isn't over. The bill now heads to the Senate, where tax practitioners and companies expect impactful changes to the mammoth legislation, including the international provisions. On this week's episode of Talking Tax, reporter Lauren Vella talks about the House provisions, what companies want to see in the Senate version of the tax bill, and how the legislation might impact US relations with other countries. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

House Republicans are moving quickly to get a massive tax-and-spending package across the finish line before week's end even as they negotiate with party factions over outstanding concerns. Some Republicans are demanding deeper cuts to social programs like Medicaid to curb deficits as part of the deal and to reduce the package's cost to extend the 2017 tax overhaul. And yet the bill increases the debt limit by $4 trillion and adds billions in spending. Cut out of the process, Democrats oppose the proposal, and even some Republicans have objected to its size and scope. Regardless of where lawmakers fall on the political spectrum, they all seem to agree on one data source: What the Committee for a Responsible Federal Budget has to say about the package and what it will do to the national deficit, which now stands at over $36 trillion. On this episode of Talking Tax, Bloomberg Tax reporter Chris Cioffi talks with Maya MacGuineas, longtime president of the nonprofit public policy group, and digs into why the growing debt can be problematic for future economic growth. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

With the massive wave of federal government layoffs, tens of thousands of workers from the IRS and other agencies are likely looking for new jobs, potentially in the private sector for the first time. Caroline Ciraolo, a partner at Kostelanetz and founder of the firm's office in Washington, D.C., has started an initiative that connects former federal tax professionals with law firms and other private employers. She knows what it's like to make the transition: Ciraolo was the No. 2 official in the Department of Justice Tax Division from 2015 to 2017 before returning to the private sector. In this episode of Talking Tax, Bloomberg Tax Editor at Large Rebecca Baker sat down with Ciraolo to discuss shifting out of government work, and how the "love of the practice area" is a key transferable skill. "That passion for unpacking complicated transactions and complicated facts and circumstances, identifying the issues—those skills are equal on both sides," she said. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.

The IRS right now isn't the same agency it was at the start of this year. That's because about 20% of IRS workers have signaled they want to leave or have been fired. The ripple effects of this exodus could go far, not just for the IRS itself, but for businesses and individual taxpayers trying to file their returns. Roughly half of the 30 people at the top of the IRS organizational chart have left, many because of Trump administration decisions that stretch boundaries of the law. Those departures in particular erode an important layer of defense to the IRS's most important missions: taxpayer data security and a fair tax system, former and current agency officials said. Most recently, two executives brought on to help the IRS build up its enforcement and reporting of digital assets left and were replaced by longtime IRS official Trish Turner. The leadership departures, combined with the broader cuts across different levels of the agency, make it harder for the IRS to collect revenue for the government and provide help to taxpayers. The IRS plans to lean more heavily on technology to make up for the lost workers. In this episode of Talking Tax, Bloomberg Tax reporters Erin Slowey and Erin Schilling discuss who's replacing executives who have left, the impacts of the high turnover, and what happens when workers who want to leave can't. Do you have feedback on this episode of Talking Tax? Give us a call and leave a voicemail at 703-341-3690.