Pillar Two Implementation: U.S. Multinationals Impacts and Considerations

International Tax Team video series – Overview of the impact of the OECD’s Pillar Two initiative on U.S. multinational groups (part 1)

Marcus Heyland

Marcus Heyland

Managing Director, Economic & Valuation Services, Washington National Tax, KPMG US

+1 202-533-3800

Chris Wilson

Chris Wilson

Tax Director, KPMG UK-US Tax Corridor, KPMG US

Look out for part 2 of this video in February that will provide an update on the current status of the Pillar Two project and
discuss further Pillar Two matters that will be particularly relevant to U.S. groups.

On December 16, the European Union achieved unanimity for an EU Directive for implementing Pillar Two. In addition, a number of other countries have taken steps towards implementation. Thousands of U.S. companies that meet the Pillar Two threshold (companies with 750 million Euro or greater of consolidated revenues) will be facing implementation issues—bringing potential financial impact in terms of cash tax and effective tax rate as well as significant incremental compliance and administrative requirements.


December 22, 2022 | In this video, Marcus Heyland, a managing director with the KMPG Washington National Tax practice and former OECD adviser, and Chris Wilson, a director with KPMG in the United Kingdom currently seconded to KPMG in the United States, discuss the potential impact of Pillar Two. After providing an overview of how Pillar Two operates, they provide:

  • Examples of the potential impact on U.S. groups, covering credit carryforwards, nonrefundable credits, and deferred tax liabilities
  • An overview of how Pillar Two may interact with the existing U.S. GILTI regime
  • A comparison of Pillar Two and the U.S. book minimum tax.

Access all International Tax Team videos


This 20-minute video was recorded on December 16, 2022.