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Global Tax Challenges: Pillar Two for U.S. Multinationals

GLOBAL TAX CHALLENGES: PILLAR TWO FOR U.S. MULTINATIONALS

Cost Free
Presentation Length 1.0 hour

Recorded DateOctober 6, 2023
CPE:Not available
(archived webinars do not offer CPE credits)
Subject AreaTaxes
Course LevelBasic
Course Description

In December 2021, the Model Rules for Pillar Two Solution (GloBE) were released with the objective of taxing large multinational enterprises (MNEs) at a 15% minimum tax rate as computed on a standardized international tax basis. This puts long-standing areas of policy into question such as tax incentives, tax competition, and low/no tax rate jurisdictions. The GloBE will be in effect in parts of Europe, Canada, Latin America, the Middle East, Asia, and Australia starting in 2024.

Join Kevin M. Jacobs and Neil Fletcher, Managing Directors at Alvarez & Marsal, Nick Crama, Director at Alvarez & Marsal, and Walid Eljaafari, CEO, co-founder and data scientist at Algonomia for an essential conversation in which they will discuss the unwelcome uncertainty caused by the rules, particularly for U.S.-parented multinational entities. They will cover the implications of GILTI, BEAT, and treaties as adoption of the GloBE in the U.S. seems unlikely in the near term.

Learning Objectives:


  • Recognize the impact of GloBE on international tax for U.S.-based companies

  • Evaluate how GILTI, BEAT, and treaties may affect U.S.-based companies under GloBE

  • Identify areas of concern for GloBE adoption in the U.S.

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PLEASE NOTE: ARCHIVED WEBINARS DO NOT QUALIFY FOR CPE
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As a Corporate Research Field Sales Representative for Wolters Kluwer Tax & Accounting, Kevin has primary responsibility for driving profitable sales growth in an assigned territory that meets or exceeds sales goals. The products sold are CCH tax, accounting, and audit research product lines. Activities include learning and staying informed on the complex and comprehensive Tax & Accounting research product lines; learning and following a comprehensive sales process (including cold calling); updating and managing sales pipeline information for an assigned list of accounts; managing time and resources effectively; representing Wolters Kluwer within the industry and territory; and contributing to the sales planning and forecasting activities.

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Neil Fletcher

Alvarez & Marsal Holdings LLC
Managing Director

(212) 759-4433

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Neil Fletcher is a Managing Director with Alvarez & Marsal’s Taxand, LLC, in London. He specializes in M&A tax transactions. His primary areas of concentration are buy-outs, carve-out transactions, and corporate joint ventures, particularly bringing complex co-invested transactions to a successful conclusion.

With more than 25 years of M&A experience, Mr. Fletcher has advised on transactions with mid-market to large-cap private equity, direct pension fund investments, and sovereign investment funds on a multinational basis across multiple industries and regions. Most recently, he served as Tax Partner in a Big Four London office. In this role, he led teams and provided technical yet practical tax advice on M&A, initial public offerings, joint ventures, and group restructurings across both domestic and international transactions for a wide variety of investors and stakeholders.

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Mr. Crama has advised Dutch and foreign investment managers, asset managers, pension funds, insurance companies, banks, family offices and REITs, specializing in direct and indirect real estate, infrastructure and debt investments. He has deep knowledge of Dutch, Luxembourg and pan-European tax as it relates to structuring investment funds and transactions.

Additionally, Mr. Crama works on tax matters related to the entire investment cycle, including transfer pricing, compliance, reporting, tax (risk) management and vendor assistance.

Walid Eljaafari

Algonomia
CEO, Co-Founder, Data Scientist

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Walid co-founded Algonomia to contribute to the transformation of tax. Being both trained in mathematics and in law, his experience in law firms made it clear how much the tax sector can benefit from new technologies powered by algorithms and data science. After several years as intrapreneurs within PwC France, his team decided to launch Algonomia and develop SaaS services for tax professionals.

About Our Presenter

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Wolters Kluwer Tax & Accounting is a leading provider of software solutions and local expertise that helps tax, accounting, and audit professionals research and navigate complex regulations, comply with legislation, manage their businesses and advise clients with speed, accuracy, and efficiency – so they maximize the impact they create for their clients. Our focus is giving tax and accounting professionals the ability to grow, manage and protect their business and their clients’ businesses in a fast-moving and ever-changing world. It means that firms can stay ahead of the pack, take advantage of new technologies, transform, and capitalize on new opportunities.

Wolters Kluwer Tax & Accounting is part of Wolters Kluwer (WKL), a global leader in professional information, software solutions, and services for the healthcare; tax and accounting; governance, risk and compliance; and legal and regulatory sectors. We help our customers make critical decisions every day by providing expert solutions that combine deep domain knowledge with advanced technology and services.