Episode 10-2022 | Due to recent developments, the widespread implementation of the OECD’s Pillar Two Global Anti-Base Erosion (GloBE) rules is now a strong probability. It seems to be more a question of when, not if. While not a single dollar (or, more accurately, a euro, pound, or won) will be collected for at least a couple years, under the Model Rules, M&A transactions entered into today can have a significant impact on GloBE tax liability tomorrow.
In this podcast, we discuss the many pitfalls that these rules may present to taxpayers currently engaging in M&A transactions. Will a tax election to step up the basis in assets on an acquisition of equity interests (e.g., a section 338(g) or section 754 election) be respected for purposes of the GloBE rules? How can the GloBE rules impact post-merger integration? How can acquisitions of goodwill and other long-lived assets expose a company to a top-up tax? How can having a JV entity included in the consolidated financial statement expose a taxpayer to a top-up tax attributable to an unrelated JV partner?
Join us as our host Gary Scanlon interviews Stephen Massed from the KPMG Washington National Tax (WNT) M&A group and Kevin Brogan and David de Ruig from WNT's International Tax group to explore these questions and more on this episode of Inside International Tax.