Episode 113: Tax Policy in Transition: From D.C. to the OECD — What to expect in 2025

TP Talks - PwC's Global Transfer Pricing podcast

In this episode of TP Talks, Kristina Novak sits down with Brett York, a Principal in PwC’s NTS Mergers and Acquisitions practice and former Deputy Tax Legislative Counsel at the US Treasury Department. Kristina and Brett discuss Brett’s experiences at Treasury, the implications of the Trump administration’s regulatory freeze, and how political appointments influence tax policy. They explore the tax guidance process, IRS leadership changes, how the US engages in OECD tax negotiations, and what the future may hold for transfer pricing—particularly under a second Trump administration.

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1. Episode 113: Tax Policy in Transition: From D.C. to the OECD — What to expect in 2025 (00:00:00)

2. Introduction (00:00:15)

3. Brett shares a memorable moment from his early days at Treasury (00:01:05)

4. Overview of President Trump’s regulatory freeze executive order and its implications for tax regulations (00:02:42)

5. How the executive order impacts proposed and pre-finalized tax regulations; typical duration of regulatory freezes (00:04:59)

6. Is a regulatory freeze typical for new administrations? Have proposed regulations been withdrawn historically? (00:07:53)

7. Status of political appointments for IRS Commissioner and Chief Counsel (00:10:02)

8. How the IRS and Treasury develop tax guidance collaboratively (00:11:52)

9. Role of the IRS Commissioner, Chief Counsel, and Treasury’s Office of Tax Policy in drafting regulations (00:12:14)

10. How political appointees influence guidance and enforcement; impact of IRS leadership changes (00:20:32)

11. Transfer pricing under Trump vs. Biden: what guidance we saw and what might be next under Trump 2.0 (00:23:08)

12. How U.S. Treasury participates in the OECD’s global tax policy development and decision-making (00:25:21)

13. Understanding the OECD Secretariat and how U.S. Treasury officials collaborate with them (00:32:32)

14. How new executive orders could impact implementation of OECD Amount B guidance (IRS Notice 2025-4) (00:35:07)

15. Final thoughts from Brett on the potential impact of incoming political appointees at Treasury (00:37:10)