Pillar Two administrative guidance and safe harbors: implications for US multinationals

Recent administrative guidance (guidance) from the Organisation for Economic Co-operation and Development (OECD) on the Global Anti-Base Erosion (GloBE) rules under Pillar Two addresses many critical issues for US multinationals but also raises many (unanswered) technical questions. The OECD’s transitional safe harbor rules, released at the end of 2022, could help relieve compliance burdens for US companies.

Join our team of Ernst & Young LLP subject matter professionals for a detailed discussion of these developments and practical approaches to help manage the reporting and tax-rate implications. We will cover:

• The “push down” allocation of taxes on global intangible low-taxed income (GILTI) to foreign subsidiaries and interaction of GILTI with qualified domestic minimum top-up taxes (QDMTTs)
• Inclusion in GloBE of stock gains/losses 
• The treatment of pre-GloBE foreign tax credit (FTC) and general business credit carryforwards 
• The application of intercompany asset transfer rules to common control transactions under US Generally Accepted Accounting Principles
• The transitional safe harbor and country-by-country reporting 

Panelists

• David Wachutka, Principal, International Tax and Transaction Services, Ernst & Young LLP
• Jason Yen, Principal, International Tax and Transaction Services, National Tax, Ernst & Young LLP
• Katherine Pinzon, Principal, Ernst & Young LLP and EY Americas International Tax and Transaction Services Transfer Pricing Leader
• Colleen O’Neill, Partner and Leader of International Tax and Transaction Services, National Tax, Ernst & Young LLP 

Moderator

• Craig Hillier, EY Americas International Tax and Transaction Services Leader

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