Cross-border Tax Talks

Threading the Needle: Pillar Two and the IRA’s Green Energy Credits

Apr 19, 2023

44:30

AI Chapters

Episode notes

Introduction

2min

What Are Good Tax Credits for Pillar 2?

3min

The Importance of Good Covered Taxes

2min

The Model Rules for Refundable Tax Credits

3min

The Differences Between Refundable Credits and Other Credits

2min

The Impact of Refundable Tax Credits on the FISQ

3min

The Impact of the Income Inclusion Rule on US Taxes

2min

The Discomfort of Converting US R&D Credit to Refundable Credit

3min

The Expansion of Green Energy Credits

2min

10.

The Transferable Credit Mechanism

3min

11.

The OECD's Guidance on Transferable Credits

3min

12.

Equity Partner Investment Structures

3min

13.

The Accounting for Investment Tax Credits Through Equity Method Investments

2min

14.

The Administrative Guidance on Equity Investments

5min

15.

The Impact of the Transferable Credit on Taxpayer Behavior

4min

16.

The OECD's Administrative Guidance on Transferable Credits

2min

Doug McHoney (PwC's US International Tax Services Global Leader) is joined by Pat Brown, seven-time veteran of the podcast, and co-leader of PwC’s WNTS practice. Pat has previously worked in the private industry for 16 years, including several years as a VP of tax and director of tax policy. After Pat chooses his most and least favorite CBTT podcasts, Doug and Pat discuss green energy credits, the Pillar Two Model Rules and administrative guidance, how the US and UK R&D credits compare under Pillar Two, refundable credits, transferable credits, the equity investment inclusion election, and qualifying flow-through tax benefits.