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Cross-border Tax Talks
July 26, 2023
Pillar Two and Financial Services: What’s the deal?
Doug McHoney (PwC's International Tax Services Global Leader) is joined by first-time guest Winnie Tang, International Tax Partner in PwC’s Financial Services practice in New York. Doug and Winnie take a rapid fire tour of the Financial Services and Deals space in light of the Pillar Two Transition Period, touching on the definitions of funds, REITs, excluded entities, management company structures, POPEs, Pillar Two in the Deals space, and many more particularities taxpayers should be aware of.
Timestamps:
- 2:00 - What challenges exist in the Financial Services space with respect to Pillar Two?
- 4:25 - Has Pillar Two and its data requirements slowed down the due diligence process?
- 5:10 - What does it mean to be a ‘fund,’ and how can they be structured?
- 7:45 - What about Real Estate Investment Vehicles (e.g., REITs)?
- 8:10 - What about other Excluded Entities under the Ultimate Parent Entity definition?
- 9:20 - What is the missing definition of revenue for Pillar Two?
- 10:40 - Does it matter what kind of industry taxpayers are in?
- 11:00 - What about management company structures?
- 12:10 - Do C-corp management structures require an analysis that differs for pass throughs, and from a consolidation perspective? How do taxpayers deal with those challenges?
- 14:30 - How are taxpayers thinking about the country-by-country safe harbors?
- 16:15 - What is the status of South Korea’s implementation of Pillar Two?
- 18:15 - What are some of the issues and challenges for deals taking place during the transition period?
- 22:50 - What challenges are we seeing in the insurance industry?
- 24:20 - What should taxpayers be considering with regards to closing dates?
- 26:55 - What about ‘Up-C’ transactions and carve out deals?
- 30:50 - What challenges exist with regard to joint venture (JV) structures?
- 34:31 - What are some general recommendations for both taxpayers and advisors who serve in this industry?
Speakers
International Tax Services Global Leader, PwC US
Winnie Tang
International Tax Partner, PwC US
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