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Although it is generally expected that the Organisation for Economic Co-operation and Development’s BEPS 2.0 initiative will have a limited direct impact on the investment fund industry, the Pillar Two model rules’ reliance on the accounting consolidation rules to determine whether a group exists will pose additional challenges when determining the scope of these rules.

The Pillar Two rules apply only to entities that consolidate on a line-by-line basis for financial reporting purposes. While investment funds generally do not consolidate with the entities in which they invest, there are certain exceptions that may apply.

This webcast will examine how the Pillar Two rules may apply to the wealth & asset management industry and will highlight practical considerations.

The following topics will be discussed:

• The current status of the Inclusive Framework’s Pillar Two discussions
• Application of the Pillar Two rules to management companies that reach the annual revenue threshold of EUR 750 million, including differences in application between structures whose ultimate parent entity (UPE) is tax transparent and Up-C structures
• Practical considerations for investment funds, such as determining the UPE, differences between consolidation requirements under US Generally Accepted Accounting Principles (GAAP) and International Financial Reporting Standards (IFRS), and the concept of excluded entities
• Pillar Two considerations for the following fact patterns:
• Single managed accounts or funds of one (e.g., insurance groups)
• Co-investments with multinational enterprises (MNEs), such as joint-ventures, partially owned parent entities (POPE) and minority investments
• Private trusts or personal holding companies for family offices and high-net-worth individuals

Date: Thursday, 13 July 2023

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

Registration: View archive here.

Panelists

Kevin J. Glen, Partner, Financial Services ITTS/FSO Central Tax Markets Leader, Ernst & Young LLP

Augusto Oliveira, Partner, Financial Services ITTS, Ernst & Young LLP

Dmitri V. Semenov, Partner, Financial Services ITTS, Ernst & Young LLP

Alex Pouchard, Partner, Financial Services International Tax Desks Leader, Ernst & Young LLP

Kerrie J. Kadugan, Managing Director, FAAS, Ernst & Young LLP

Moderator

Jun Li, Partner, Financial Services Wealth and Asset Management Tax Leader, Ernst & Young LLP

CPE credit offered: up to 1.2 depending on duration. Recommended field of study: Taxes. Learning objectives: Assess the current status of Pillar Two discussions and progress globally; identify how the Pillar Two model rules might apply to management companies with revenue above the applicable threshold; recognize specific Pillar Two considerations that may be relevant for various fact patterns in the wealth & asset management sector. 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 | lynn.fairfax@ey.com and Barbara Kirchheimer | Barbara.Kirchheimer@ey.com

Learn about and register for EY Tax webcasts

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