Pillar Two Technical Series: GloBE Interaction With US Tax Regime

In our final session of the 10 part series, we will explore the current interactions with the US tax regimes and current GloBE Rules. In so doing, we will discuss the February 2023 Adminstrative Guidance's commentary on the US GILTI Regime and the June 2024 Administrative Guidane for the allocation of cross border CFC taxes. A panel discussion about how these provisions affect MNE Groups today will conclude the series with forward implications of what may come. Upon completion of this program, participants will be able to: Discuss Pillar Two planning strategies. Describe reorganization considerations around Pillar Two planning. Recognize the implications of Pillar Two on loss-making entities.