Spotlight on BEPS 2.0: developments and practical implications for US MNEs - June 2024

In this webcast, panelists discuss the recently released OECD administrative guidance.

On June 17, 2024, new guidance on the Global Anti-Base Erosion (GloBE) rules under Pillar Two was issued by the OECD/G20 Inclusive Framework on BEPS (Inclusive Framework). The new guidance addresses many critical technical issues for US multinationals. That same day, the Inclusive Framework also released supplementary elements relating to the report on Amount B of Pillar One.

Join our team of Ernst & Young LLP subject matter professionals for a detailed discussion of these developments. We will cover:

• The computation of deferred taxes for purposes of GloBE, in connection with GloBE versus financial accounting basis differences
• The “push down” allocation of current and deferred taxes to permanent establishments, controlled foreign corporations and hybrid entities
• The allocation of profits and taxes in tiered flow-through structures 
• The revisions to the deferred tax liability recapture rules
• The OECD’s process for recognizing the qualified status of each jurisdiction’s adoption of the GloBE rules, including a special transitional qualification process
• The definitions of qualifying jurisdictions within the meaning of the Amount B guidance

Panelists

• Katherine Pinzon, Principal, Ernst & Young LLP and EY Americas Transfer Pricing Leader and US-West Region Transfer Pricing Leader
• David Wachutka, Principal, International Tax and Transaction Services, Ernst & Young LLP
• Jason Yen, Principal, International Tax and Transaction Services, National Tax Department, Ernst & Young LLP

Moderator

• Colleen O’Neill, Director of International Tax and Transaction Services, National Tax Department, Ernst & Young LLP

EY webcast managed and produced by Ernst & Young LLP’s Tax Technical Knowledge Services Group, Washington, DC: Lynn Fairfax