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February 16, 2023

Thursday, March 9 | Pillar Two administrative guidance and safe harbors: Implications for US multinationals (1 pm ET)

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

Date: Thursday, March 9, 2023

Time: 1:00-2:15 p.m. ET New York; 10:00-11:15 a.m. PT Los Angeles

Registration: View archive here.


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


Craig Hillier, EY Americas International Tax and Transaction Services Leader

CPE credit offered: 1.4. Recommended field of study: Taxes. Learning objectives: Identify the tax policy implications of the OECD's recent administrative guidance on Pillar Two; assess how the latest developments may affect the tax rates and reporting obligations of US multinational companies. This intermediate level, group internet-based course has no prerequisites or advanced preparation. Final CPE award to be based on content, polling and length of participation. See CPE FAQ for more information.

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

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