In late December, the OECD released model rules for implementing the new 15% global minimum tax, part of the two-pillar approach to addressing the challenges of the digital economy. In this episode, we walk through the latest guidance regarding the GloBE rules, provide an update on the implementation process for this new regime, and consider some practical aspects of global implementation. How do these model rules address timing differences? Could Pillar One political obstacles in the United States derail Pillar Two implementation? How might U.S. failure to legislate the necessary GILTI and BEAT changes affect the global consensus? Finally, what does the EU directive tell us regarding the implementation process of Pillar Two?
Our host Gary Scanlon interviews Quyen Huynh, a principal in the International Tax group of the KPMG Washington National Tax practice and recently the Deputy International Tax Counsel for Treaty Affairs at the Treasury Department, and Marcus Heyland, a managing director in the Economic & Valuation Services group of the Washington National Tax practice and recently an adviser at the OECD on BEPS 2.0.