IFA USA DC Regional Webinar- GILTI becomes a Qualifying IIR – Now What?

About the webinar

Date: Wednesday, July 27 2022
Time: 12:00-1:00 PM ET

Don’t miss this exciting and timely discussion of the implications of Pillar 2 for U.S. companies if the reforms to GILTI in the House-passed version of the Build Back Better Act (BBBA) are enacted. This panel will assume that the reforms contained in BBBA would result in the rest of the world treating GILTI as a Qualifying IIR. The panel will explore the next step in the analysis, which is, what does it mean for GILTI to be a qualifying IIR and what aspects of Pillar 2 would remain relevant to U.S companies? For example, the panel will discuss what impact Pillar 2 may continue to have on US parent entities, foreign disregarded entities and branches, U.S. intermediate holding companies, partially-owned parent entities, as well as the Pillar 2 reporting and compliance requirements that may remain for U.S. based companies. To the extent that enactment of BBBA is no longer viable at the time of the panel, the panel will instead discuss the implications of Pillar 2 on US companies in the absence of US tax reform, including discussing different methods for allocating GILTI taxes to foreign entities for Pillar 2 computation purposes.

Learning objectives:

• Understand how Pillar 2 will apply if BBBA is enacted and GILTI is reformed.
• Understand how Pillar 2 will apply in the case of foreign parented US intermediate holding companies
• Understand the reporting and compliance requirements of US based companies under Pillar 2.

Moderator:

Jason Yen, Principal, EY

Panelists:

Joshua Odintz, Partner, Holland & Knigh
Danielle Rolfes, Principal, KPMG
Robert Stack, Managing Director, Deloitte(Potential government panelists to be named later)