Events

2023 75th Anniversary Annual Conference

Sponsor & Presenter

Pillar Two Boot Camp + Interactive Case Study

EARLY BIRD REGISTRATION IS OPEN THROUGH OCTOBER 20th

WEEK 1

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

WEEK 2

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:

• https://www.oecd.org/tax/beps/administrative-guidance-global-anti-base-erosion-rules-pillar-two-july-2023.pdf
• https://www.oecd.org/tax/beps/globe-information-return-pillar-two.pdf

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.