Cross-border Tax Talks

PwC

PwC specialists share insights and perspectives on key issues impacting the ever-changing tax landscape. Our podcasts aim to provide quick, easy and up-to-date tax developments to help you stay current and competitive in today's challenging business environment. Listen to episodes at your convenience via your desktop computer or smart device.

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Cross-border Tax Talks

Episodes (205)

Thu Feb 12th In Jeopardy: Sovereign wealth funds and Section 892
Jan 29th Geopolitical reset: Stability and Agility in 2026
Jan 15th The Global Tax Journey: 2025 to 2026

Cross-border Tax Talks

Feb 12, 2026
40 minutes
28 MB

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Nils Cousin, an international tax partner in PwC’s Washington National Tax Services Practice, for his fourth appearance on the show. Doug and Nils discuss Nils’s April 2024 Jeopardy experience before pivoting to the 1916-era Section 892 exemption: how foreign governments, sovereign wealth funds, and public pension funds use it, and how ‘commercial activity’ and ‘controlled commercial entity’ rules can taint the benefit. They unpack the December 2025 regulation package, highlighting what was finalized (including an inadvertent-activity cure period, the qualified partnership exception, and FIRPTA taint relief) and what remains propos...

Cross-border Tax Talks

In Jeopardy: Sovereign wealth funds and Section 892

PwC

00:00 -40:06