International Tax forum

Understanding Pillar Two: Mechanics and financial operating model impact

Over 135 countries have agreed to implement global tax reforms, including a global minimum effective tax rate, under the Organisation for Economic Co-operation and Development’s Inclusive Framework. Pillar Two compliance will challenge the financial operating model of every global organization to which it applies. This session will use examples to showcase the technical mechanics of Pillar Two compliance and highlight the challenges and opportunities multinational enterprises will face as they move toward operational readiness.  

Presenters:

Larry LeBlanc, Partner, RSM US LLP

Duncan Nott, Partner, RSM UK

Advance pricing agreements and other dispute resolution opportunities

Uncertainties and expenses can stand between internationally active businesses and cost-effective, efficient transfer pricing strategies. Fortunately, tools such as advance pricing agreements and mutual agreement procedures can help multinationals clear common hurdles, limit taxation and mitigate risks. While APAs provide a non-adversarial alternative and proactive process to resolving transfer pricing disputes, MAPs are a useful dispute resolution tool for taxpayers facing transfer pricing assessments that result in double taxation. This session will explain how APAs and MAPs help resolve international tax controversies and create international tax planning opportunities.

Presenters:

Global VAT in the digital age: Staying ahead of evolving compliance requirements

Rules for reporting the sale of digital goods and services continue to change, making it difficult to ensure compliance. With DAC7 and ViDA on the horizon, the pace isn’t slowing down. It is more important than ever to ensure reporting, reviews and validation of your VAT filings are accurate. This session will discuss the latest developments in the digitalization of VAT compliance and help you understand how ongoing changes could impact your business.

Presenters:

Steering clear of double taxation using foreign tax credits

U.S. multinational businesses have relied on the U.S. foreign tax credit system to avoid getting taxed twice and minimize their global effective tax rate. In a perfect world, this system would allow businesses to use their foreign taxes as a dollar-for-dollar credit to reduce their U.S. tax liability. There have always been limitation rules that restrict the ability to claim these credits, and Treasury has recently passed additional restrictions around the areas of cost recovery and attribution rules, among others. This session will help businesses grasp the importance of foreign tax credits and understand how various restrictions may apply to your business.

Presenters:

Rob Schmidt, Principal, RSM US LLP