Name
International/Corporate Taxation: Thoughts on a Side-by-Side System: What are the Primary Issues Raised and What Solutions Make the Most Sense?
Speakers
Michael Plowgian, KPMG US LLP
Silke Bruns, German Ministry of Finance
Tadd Fowler, Procter & Gamble
Carolina Perez-Lopez, Johnson & Johnson
Achim Pross, Organisation for Economic Cooperation and Development Centre for Tax Policy and Administration
Isaac Wood, U.S. Department of the Treasury
Silke Bruns, German Ministry of Finance
Tadd Fowler, Procter & Gamble
Carolina Perez-Lopez, Johnson & Johnson
Achim Pross, Organisation for Economic Cooperation and Development Centre for Tax Policy and Administration
Isaac Wood, U.S. Department of the Treasury
Date & Time
Thursday, January 8, 2026, 2:15 PM - 3:30 PM
Description
This panel will discuss the Pillar Two guidance that is expected to be released by the OECD/G20 Inclusive Framework on BEPS shortly before the conference. The guidance is expected to address the side-by-side system for U.S. parented multinationals, the treatment of nonrefundable tax incentives, and other safe harbors. We will focus on the potential impact on U.S. parented multinationals and where Pillar Two may be going from here.
Virtual Session Link