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The Side by Side Package: OECD’s New Framework for Global Minimum Tax
Tax
Webcast

The Side by Side Package: OECD’s New Framework for Global Minimum Tax

This webcast explains the Side by Side package, which allows for a U.S. exemption from Pillar Two, thereby easing international tax compliance while still complying with OECD’s global minimum tax directive.

$39 - $59
Do you have an AICPA or CIMA membership? Log in to apply your member discount.

Format

Webcast

Date

Feb 24, 2026

NASBA Field of Study

Taxes

Level

Intermediate

CPE Credits

1

Instructor

Ryan Bowen, Phil Ramstetter, Cory Perry

Availability

3 months

Product Number

WC5218906

 View  
 Business & partner 
Product Details

The newly approved Side by Side (SbS) package of the Organisation for Economic Co-operation and Development (OECD) marks a major step forward in the coordinated operation of the global minimum tax (Pillar Two).

This session examines how the SbS package introduces:

  • New safe harbors
  • Simplified effective tax rate calculations
  • A notable U.S. exemption designed to ease compliance burdens for multinational enterprises

Participants will gain practical insights into how these changes affect U.S. multinationals, what the safe harbors mean in practice, and how tax leaders can strategically position their organizations to:

  • Reduce risk
  • Enhance certainty
  • Prepare for the future in a rapidly evolving international tax environment

Key Topics

  • Overview of the OECD Side by Side (SbS) package
  • Understanding the U.S. exemption
  • How SbS safe harbors reduce compliance complexity
  • Strategic tax planning under the SbS framework
  • Operational and data impacts
  • Enhancing internal readiness

Learning Outcomes

  • Differentiate the key components of the OECD Side by Side package, including new safe harbors for Qualified SbS Regimes, substance-based non-refundable tax incentives, and the simplified effective tax rate (ETR) rules.
  • Determine the scope and implications of the U.S. exemption, and how it affects multinational groups headquartered or operating in the United States.
  • Determine how the SbS safe harbors reduce compliance complexity under Pillar Two and where they may provide relief for affected entities.
  • Distinguish strategic tax considerations, including how to leverage simplified rules while preparing for global minimum tax implementation.
  • Analyze operational impacts, such as data requirements, reporting adjustments, and cross-jurisdictional coordination.
  • Apply insights to strengthen internal readiness and reduce uncertainty in global minimum tax compliance.

Who Will Benefit

CPAs, international practitioners, large firms, medium firms

Credit Info
CPE Credits
1
NASBA Field of Study
Taxes
Level
Intermediate
Prerequisites
Basic understanding of international taxation
Access
This is a digital product. With full paid access the content will be available to you for 3 months after purchase date.
Duration
1 hr
For more information, please refer to CPE requirements and NASBA sponsorship information
Pricing
Do you have an AICPA or CIMA membership? Log in to apply your member discount.
Nonmembers
$59.00
AICPA Members
$49.00
CIMA Members
$49.00
Tax Section Members
$39.00

Group ordering for your team

2 to 5 registrants

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6+ registrants

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US customers call 1-800-634-6780 (option 1)

Contact us
Speakers
Ryan Bowen
J.D.
Ryan Bowen is a Principal at Deloitte Tax LLP in the International Services Group of the Washington National Tax (WNT) Office. Ryan joined Deloitte in 2017 following a 7-year career at the IRS Office of Associate Chief Counsel, International. While at the IRS Ryan worked on guidance under Secs. 367 and 721(c). He currently leads WNT’s Pillar Two efforts and advises clients on general issues in outbound taxation. He received his B.S. from University of Pittsburgh and his J.D. from George Washington University School of Law. Mr. Bowen is a licensed member of the Maryland Bar.
Phil Ramstetter
CPA
Phil Ramstetter is a Partner in PwC’s International Tax Services practice based in Chicago, IL. Phil’s practice focuses on mainly on international tax matters including complex international structuring; holding and finance companies; inbound and outbound international tax issues; U.S. and foreign acquisition structuring and integration; efficient cash redeployment and repatriation; and foreign tax credit analysis. Phil also has extensive experience in OECD and global tax matters, including a secondment to Business at OECD in early years of the OECD’s digital project - now known as the two pillar solution (i.e., Pillar 1 and Pillar 2). This involves regular advice to several U.S. headquartered and foreign headquartered MNEs on the impact of proposed rules (including structural and computation issues). Phil joined PwC in September of 2013 in Cincinnati and transferred to Chicago in 2014. Phil has his JD from the University of Cincinnati and a Bachelor’s degree in Accounting from The Ohio State University. He is a CPA licensed to practice in Illinois and Ohio and is admitted to the Ohio Bar (inactive status). Phil frequently speaks and writes on a broad range of international tax issues including the OECD’s initiatives as well as U.S. law and regulatory changes.
Cory Perry
CPA
Cory Perry, CPA, is a Partner of International Tax at the Washington National Tax Office of Grant Thornton. He consults on various international and transactional tax matters, including cross-border restructuring and financing, subpart F, global intangible low-taxed income, foreign tax credit planning, Pillar 2 and global tax strategy. Cory’s work focuses on international quantitative consulting, as well as consulting services for mergers and acquisitions. He has significant experience performing earnings and profits studies and foreign tax credit studies for companies ranging up to large public and private clients, including Fortune 100 companies. Cory has written, spoken and lectured on a wide variety of topics including tax reform, subpart F, global intangible low-taxed income, section 367, and financial statement implications for U.S. multinationals. In addition to his work at Grant Thornton, Cory is chair of the AICPA’s International Tax Resource Panel and its OECD Task Force, where he helps guide the profession’s engagement with emerging international standards.
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