Model rules that give effect to the GloBE rules are due to be developed by the end of November 2021. So, we should have an early opportunity to consider some of the key issues including the rules’ design, operation and scope, as well as the effective tax rate calculation. We will consider the carve outs and exclusions and how GloBE and GILTI may co-exist.

We will also consider practical issues, such as how an agreement at OECD will impact US tax reform and whether the GloBE proposal is the only way forward now. Finally, do taxpayers and tax authorities have certainty at last? What are the practical considerations of working within this new environment?