Participants will apply Pillar Two rules to a detailed hypothetical MNE scenario, analyzing top-up tax exposure, interaction with U.S. GILTI, and safe harbor eligibility.
Learning Outcomes:
- Identify jurisdictions triggering top-up taxes using practical case facts.
- Evaluate the interaction of IIR, UTPR, and QDMTT in a multi-jurisdiction scenario.
- Apply deferred tax and safe harbor principles to a complex fact pattern.
Who Should Attend:
In-house tax professionals involved in OECD Pillar Two compliance, planning, or policy for their employer.
Instructor(s):
Pat Brown, Partner, National Tax Office Co-Leader, PwC
Steven Kohart, International Tax Principal, PwC
General Course Information
Access
Online, upon completion of the checkout process, you will be directed to our Learning Management System (LMS) for access to the full course.
For member pricing, please login to tei.org
This is a digital product. With full paid access, content will be available for one year after the purchase date.
CPE Credits
This digital product is not eligible for Continuing Professional Education (CPE) credit.
This session includes recordings from the 2025 virtual program and the corresponding PowerPoint slides.
Length of Course
This session will take approximately 1.5 hours to complete.
NASBA Field of Study
Taxes
Level
Basic
Prerequisites
None
For more information, please refer to CPE requirements and NASBA sponsorship details.
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