Pillar Two - A Primer  

Upon successful completion of this course, the user should be able to:

• describe the fundamental aspects of the OECD's involvement in international tax policy,

• identify the chief components and issues of the OECD's Pillar One and Pillar Two,

• summarize the significance of the role of financial statements in the Pillar Two Framework,

• explain the applicability of Pillar Two to a multinational enterprise considering the relevant revenue threshold,

• list the primary components for calculating the global minimum tax rate for the multinational enterprise,

• describe the types of taxes within the definition of covered taxes,

• explain the elemental aspects of the income inclusion rule, the undertaxed payments rule, and the qualifying domestic minimum top-up tax rule,

• describe the importance of domestic implementing legislation and cite the progress made thus far, and

• explain the issues U.S. multinationals will encounter due to Pillar Two and the U.S. Subpart F and GILTI rules.