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In December 2021, the Organisation for Economic Co-operation and Development (OECD) published a widely anticipated “two pillar” model rule for domestic implementation of a 15% global minimum tax.

Heather Horn was joined by Jennifer Spang, PwC National Office partner, and Pat Brown, PwC’s Washington National Tax Services Co-Leader, to discuss the challenges and taxation implications of the OECD model rule, along with considerations for how companies can prepare.

In this episode, you will hear:

• 1:30 - A refresher on the role of the OECD 
• 4:16 - The evolution of a global minimum tax and potential challenges countries face in adopting the model rule
• 11:56 - Potential interpretations that could impact how countries enact and enforce the model rule
• 20:54 - An overview of the rules and how they create the concept of a minimum effective tax rate
• 25:38 - Adjustments to financial statement income to arrive at global income
• 32:18 - How the global minimum tax computation of the model rule is creating US domestic tax policy implications
• 41:26 - Considerations on how to prepare for rule adoption

Want to learn more? Read the proposed rules, commentary, and illustrative examples. Also, listen to our previous podcast, What global tax initiatives could mean for your company.

Jennifer Spang is PwC’s National Office income tax accounting leader specializing in tax accounting under US GAAP and IFRS. She has over 25 years of experience helping companies in a variety of industries navigate complex tax accounting matters.

Pat Brown is PwC’s Washington National Tax Services Co-Leader. Prior to joining PwC, he spent 16 years in the private sector, including a role as the director of tax policy for a Fortune 50 company. Pat has also served in the US Treasury’s Office of Tax Policy as an attorney-advisor and as Associate International Tax Counsel.

Heather Horn is PwC’s National Office thought leader, responsible for developing our communications strategy and conveying firm positions on accounting and financial reporting matters. She is the engaging host of PwC’s accounting and reporting weekly podcast and quarterly webcast series. With over 30 years of experience, Heather’s accounting and auditing expertise includes financial instruments and rate-regulated accounting.

Transcripts available upon request for individuals who may need a disability-related accommodation. Please send requests to [email protected].