Steve Kohart, PwC international tax partner and former OECD adviser, joins Doug McHoney to discuss the OECD's Pillar Two Administrative Guidance. They cover topics like safe harbor implementation, purchase price adjustments, hybrid arbitrage arrangements, CFC tax allocation, and potential additional guidance in 2024.

Steve Kohart, an International Tax Partner at PwC and former OECD advisor, shares valuable insights into the complexities of Pillar Two in international taxation. He discusses the Qualified Domestic Minimum Top-Up Tax (QDMTT) and the global implications for multinationals, particularly in Puerto Rico. The conversation delves into challenges around year-end compliance and data readiness, as well as pitfalls like hybrid arbitrage and financial statement finalization. Kohart also clarifies the concept of a 'good' credit under these new regulations.