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ITPF | Georgetown Law Conference 2024 – The U.S. Confronts Pillar Two
Register here to attend in-person or virtually
Please join the Georgetown Law’s Institute of International Economic Law (IIEL) and the International Tax Policy Forum (ITPF) for the 2024 ITPF / Georgetown Law Conference – The U.S. Confronts Pillar Two, on Friday, April 5, 2024 in-person at Georgetown Law and virtually via Zoom.
In October 2021, over 135 jurisdictions approved the OECD Statement on a Two-Pillar Solution to Address the Tax Challenges Arising from the Digitalization of the Economy. Pillar Two sets forth a 15% global minimum tax (GMT) on companies with revenues above €750 million that countries may choose to adopt. To date, around 50 jurisdictions have taken steps to implement the GMT, including half the G20 and all EU member states.
While the GMT was in part inspired by the U.S. Global Intangible Low-Tax Income (GILTI) rules, GILTI is not treated as meeting the requirements of the GMT because it does not operate on a country-by-country basis. Accordingly, unless GILTI is amended, US multinationals may be subject to both GILTI and GMT on their foreign income (as well as the U.S. Corporate Alternative Minimum Tax). In addition, under the enforcement rules of Pillar 2, foreign governments may impose GMT on the domestic income of any U.S. companies that may be subject to an effective tax rate of less than 15%, if the United States Congress does not instead choose to claim that revenue. The application of Pillar 2’s enforcement rule by foreign sovereigns could also potentially negate the benefit of the U.S. R&D tax credit and certain other U.S. tax incentives for taxpayers subject to an effective tax rate of less than 15%, absent changes in the way these incentives are structured under U.S. law.
This conference will review the status of GMT guidance and worldwide implementation, assess the U.S. and global revenue effects, consider potential responses of countries and companies to the GMT, and discuss what the United States should do in response to GMT adoption by other countries.
Preview the 2024 conference agenda here.
Access the conference live stream here.
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Global Trade Academy 2024 – The Law and Policy of International Trade
The Georgetown University Law Center and the Institute of International Economic Law are delighted to announce that the 2024 Global Trade Academy will take place in-person on April 15-17 at the Georgetown University Law Center and April 18-19 at the law offices of King & Spalding in Washington, DC. For the first time since the pandemic, the Academy will meet live in the heart of the nation’s capital, bringing together participants from governments, IGOs, NGOs, and the private sector, and allowing attendees to meet and exchange views with leading experts as well as participants from around the world.
Every year, the Global Trade Academy tackles tough questions by providing participants with a custom-designed program that explores the legal foundations of the global trading system, the role of regional trade agreements, and the evolution of national policies in the face of rapidly changing global priorities and heightened geopolitical rivalries. Through presentations, interactive policy conversations, breakout/networking sessions, a simulation, and a keynote speech, participants will learn from leading experts about core rules regulating international trade, as well as the most recent developments and disputes shaping the global economy.
For more information, please view our brochure and agenda for the 2024 Global Trade Academy.
Who should attend? Diplomats, legal professionals, trade policy officials, members of the international business, IGO and NGO communities, academics, and others – including those from developing countries and transition economies. By design, this Executive Education program is open to more experienced leaders and younger professionals alike. One need not be an attorney to attend.
Continuing Legal Education (CLE)
The 2023 Global Trade Academy offered participants 29 CLE credits, and we anticipate offering a similar number of CLE credits for this year’s program.
For any questions, please do not hesitate to reach out to the Institute’s Interim Executive Director, Zainab Ahmed at za190@georgetown.edu.