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Episode 10-2022 | Due to recent developments, the widespread implementation of the OECD’s Pillar Two Global Anti-Base Erosion (GloBE) rules is now a strong probability. It seems to be more a question of when, not if.  While not a single dollar (or, more accurately, a euro, pound, or won) will be collected for at least a couple years, under the Model Rules, M&A transactions entered into today can have a significant impact on GloBE tax liability tomorrow.

In this podcast, we discuss the many pitfalls that these rules may present to taxpayers currently engaging in M&A transactions. Will a tax election to step up the basis in assets on an acquisition of equity interests (e.g., a section 338(g) or section 754 election) be respected for purposes of the GloBE rules? How can the GloBE rules impact post-merger integration? How can acquisitions of goodwill and other long-lived assets expose a company to a top-up tax?  How can having a JV entity included in the consolidated financial statement expose a taxpayer to a top-up tax attributable to an unrelated JV partner?

Join us as our host Gary ScanlonÌý¾±²Ô³Ù±ð°ù±¹¾±±ð·É²õÌýStephen Massed from the ÀÖÓ㣨Leyu£©ÌåÓý¹ÙÍø Washington National Tax (WNT) M&A group and Kevin BroganÌý²¹²Ô»å David de Ruig from WNT's International Tax group to explore these questions and more on this episode of Inside International Tax.