The Art of the Global Tax Deal

In this episode of Inside International Tax, we discuss the concessions the United States is seeking from the OECD’s Inclusive Framework on the Pillar Two regime to protect U.S. multinationals from over-taxation and the potential international response to these demands. 

While the United States has not adopted the Pillar Two regime, and indeed the Trump administration and Republicans in Congress have expressed outright hostility to the regime, more recently, U.S. multinationals may still be subject to Pillar Two taxes levied by other countries. However, in addition to threatening retaliatory measures, the Trump administration has approached the OECD’s Inclusive Framework to negotiate for the co-existence of Pillar Two and the U.S tax system. Why should U.S. companies be concerned about Pillar Two? What reforms to Pillar Two does the administration seek and would these “tilt the playing field” toward the United States vis-à-vis other members of the Inclusive Framework? How does the expiration of the UTPR safe harbor impact the timing of the negotiations, and how have the members of the Inclusive Framework responded to the administration’s entreaties thus far?  Finally, can the United States and the world find a harmonious path forward on Pillar Two?

Join us as our hosts Gary Scanlon and Kristen Gamboa interview returning guest Michael Plowgian from KPMG’s WNT International Tax group to answer these questions and more on the latest episode of Inside International Tax.