Pillar Two from a US perspective

In this episode Christian Kaeser and Arne Schnitger have a lively
discussion with Itai Grinberg, Professor of Law at the Georgetown
University Law Center and former Deputy Assistant Secretary
(Multilateral Negotiations) at the Office of Tax Policy of the
United States Department of the Treasury who was in this position
the lead US delegate for the Two Pillar solution agreement. Itai
gives interesting insights regarding the negotiation process and
the challenge of diversity of perspectives within the Inclusive
Framework and the OECD. They discuss the complexity of the Pillar
Two rules from a US and German perspective, the latest OECD
Guidance from December 2023 regarding (temporarily) safe harbours
and the balance between the need for simplification and the attempt
to prevent avoidance. Finally Itai shares his thoughts about the
biggest achievement and the biggest failure of the negotiation
process around the Pillar Two model rules and gives a short outlook
about crux climate, a digital platform to transact and manage
transferable tax credits.