2023 75th Anniversary Annual Conference


2023 75th Anniversary Annual Conference


2023 75th Anniversary Annual Conference

Sponsor & Presenter

October 22-25, 2023 | New York City
More Information

Pillar Two Boot Camp + Interactive Case Study



Technical Sessions  – 6 Modules M/W/F at 10 AM and 2 PM CDT – 9 CPE Hours

  1. OECD Guidance and Legislative Update
    1. Overview of OECD Guidance
    2. Jurisdictional Update
    3. Subject to Tax Rule (STTR)
  2. Top-Up Tax and Tax Accounting
    1. Operational Rules
    2. GloBE Income Adjustments
    3. Tax Adjustments
  3. Charging Provisions
    1. Qualified Domestic Top-up Tax (QDMTT)
    2. Income Inclusion Rule (IIR)
    3. Under Taxed Profit Rule (UTPR)
  4. Pillar Two Safe Harbours and Elections
    1. Safe Harbours
    2. Elections
    3. Penalty Relief
  5. Interplay with U.S. Tax Calculations
    1. S. Ultimate Parent Entity (UPE)
    2. Foreign UPE with U.S. Sandwich Structure
    3. UPTR Safe Harbour
    4. Corporate Alternative Minimum Tax (CAMT)
  6. GloBE Information Return
    1. Coordination Pillar Two Operational Rules
    2. Simplified Filing Requirements
    3. Surrogate Entity Jurisdiction


Interactive Case Study – 5 hours of CPE

Participants work through a live fully-integrated Pillar Two Case Study in 5 sessions.

  • Case Study Introduction and Financial Accounting Net Income or Loss
    • Legal Structure
    • Jurisdictional Tax Attributes
    • Financial Accounting Net Income or Loss (FANIL)
    • Chart-of-Accounts
    • Trial Balances
  • Tax Purposes, Adjustments and Country-by-Country Report
    • Tax Purposes
    • Adjustments
    • Country-by-Country Report
    • IRS Form 8975
  • U.S. Tax Calculations and Pillar Two Reports
    • Operational Rules
    • GILTI, FDII and FTC
    • Transitional Safe Harbour Report
    • Pillar Two Report
  • GloBE Information Return
    • MNE Group Information
    • Jurisdictional Safe Harbours and Exclusions
    • GloBE Computations
  • Wrap-Up and Final Polling and Q&A
    • Jurisdictional Attributes
    • FANIL and Adjustments
    • S. Tax Calculations
    • Pillar Two Reports
    • GloBE Computations

Up to 14 CPE

This session covers OECD Guidance including the following two OECD documents published as of July 13, 2023:


Specific learning objectives participants will derive from this session include:

  • Understanding the new Qualified Domestic Top-Up Tax (QDMTT) Safe Harbour
  • Understanding the Transitional UTPR Safe Harbour for Jurisdictions subject to a Tax Rate of at least twenty percent
  • Understanding the new guidance on tax credits including transferable credits
  • Understanding the final changes to the GloBE Information Return (GIR)

A brief Case Study is also presented to reinforce the Pillar Two calculation methodology focusing on how the Pillar Two rules interplay with U.S. tax law.

Program Field of Study: Taxes
Program Level: Intermediate
# of CPE credits: Up to Fourteen (14)
Advanced Preparation: None
Prerequisite: Intermediate education or experience in International Taxation is required in order to fully appreciate content provided in this program.

Refunds are not available, except for duplicative registrations.

November 27-8, 2023 | Webinar
More Information

Insights & Press

VantagePoint™ performs comprehensive global tax calculations, including GILTI, FDII, FTC and BEAT in real-time.

Forte has a customized approach utilizing VantagePoint that ranges from consulting engagements to a full license of the software.

Play Video

"With passage of the tax reform legislation, there were many new provisions, including GILTI, FDII, BEAT, and 163(j), that needed to be dealt with...[VantagePoint] was pretty far advanced and ready to go."


quote icon

“With passage of the tax reform legislation, there were many new provisions, including GILTI, FDII, BEAT, and 163(j), that needed to be dealt with…[VantagePoint] was pretty far advanced and ready to go.”

Check out the second installment of “Tax Technology Corner” where Tax Executive Institute explores how Forte helps multinationals solve today’s most complex tax challenges using VantagePoint™ Global Tax Software.

Mark Gasbarra writes on Global Tax Integration and the GILTI/FDII/FTC Interplay for the ACT Tax Tech eNews. Download a Copy

Forte combine international tax expertise in conjunction with the most advanced, versatile, and powerful global tax software tool in the industry.

Forte focus specifically on those areas of international taxation that have the greatest impact on U.S.-based multinationals and exporters.

VantagePoint™ provides a centralized data hub, which helps companies manage their global tax position throughout the year.