Thread by @SoongJohnston

After a long hiatus (thanks, COVID!) #OECDTaxConference kicks off with introductory remarks from Rick Minor @USCIB Fabrizia Lapecorella of @MEF_GOV and Tim McDonald of @ProcterGamble. Watch for @TaxNotes coverage from me, @PaezWrites and @KiarraStrocko

Lapecorella gives a broad overview of the state of the two pillar project but notes "beyond the two pillars, there is life," she says, to laughs to the audience. Other projects including the inclusive forum on carbon mitigation approaches and tax treatment of cross-border workers

It's a really monumental day, this is a really important point in tax policy evolution. We're on the cusp of announcing the the remaining elements of the pillar 1 deal, says MacDonald #OECDTaxConference

I'm hopeful for its success, and I think we're all are committed to it. Unlike prior projects, it's the governments that are dictating the path, says MacDonald. Window for participation is 14 days for amount A consultations, taxpayers must get involved, he says

It's in all our interests for this to succeed, and the risk of failure is out there. If it does fail, we could have a much worse situation that what we've seen in recent years, and that's what we're trying to avoid, MacDonald says

Next up: the panel on the 2-pillar solution to tax challenges of digitalization of the economy with @PSaintAmans @ItaiGrinberg Martin Kreienbaum, Alan Maclean Lisa Wolski of GE, Tom Hutchinson of Google #OECDTaxConference

.@PSaintAmans: I'm not going to say any breaking news so Stephanie and @IsabelGottlieb don't have to tweet anything right now (ha!)

Since the October agreement, your government officials have been working like crazy, day and night, 24/7 to implement. On P2: We still owe you the implementation framework. On P1: It's clear we won't have a multilateral convention to sign in July says @PSaintAmans

PSA: IF is working on a proposal for a revised schedule for P1. People will get a chance to look at all building blocks as a package. We'll break the news to the G20 finance ministers if there is news but it will be a combination of being realistic and being ambitious

PSA: If P1 doesn't happen, it's a good question you should collectively think of. We have a package which is politically agreed, P2 is ready for implementation, question is, who shoots first? It's a question of time and then there will be a domino effect with the first mover

For those questioning whether P1 is going to happen and its timeline, I can tell you officials are negotiating as if their lives are depending on it, which means it'll probably happen, says @PSaintAmans #OECDTaxConference

Germany is a strong believer in multilateralism because with multiple coordination, we can avoid double and multiple taxation, says Kreienbaum

P2 may be a chance to have a comprehensive approach to what we think is harmful tax competition maybe we can integrate what countries have in terms of CFC and defensive measures, says Kreienbaum #OECDTaxConference

.@ItaiGrinberg: Pillar 2 levels the playing field, full stop. Strengthening GILTI will minimize current incentives for profits abroad while in an environment where everyone else is committed to do the same

Pillar 1 is in our interest because it will help stabilize the international tax system. DSTs are just the tip of the iceberg. What's more important is addressing cross border tax controversy. We're committed to P1 says @ItaiGrinberg

A tease from @ItaiGrinberg: You'll see a significant public release soon, which will provide timelines for public responses that are substantially longer than two weeks. You'll see most of ingredients on table but the cake has not yet been made. 🎂

Hutchinson: @Google's priorities for this project: We want a stable regime, tax certainty, administrability, and I'm pleased to hear we'll have more time to comment on pillar 1, these are big important changes so we have to have enough time to get it right #OECDTaxConference

McLean: Some areas that are important before we get the package done include dealing with enormous complexity. We believe there are administrative options that will enable some of the complexity to be reduced/eliminated, like increased use of safe harbors

Wolski: We don’t understand why the US should strengthen its GILTI before other countries adopt their minimum taxes, it doesn’t make any sense. #OECDTaxConference

Wolski: Once other countries have adopted and implemented P2, US must modify GILTI so it matches in every respect, including treatment of historic losses and substance-based carveout. The P2 construct is a far superior to the GILTI structure.

Wolski: I worked in the Senate for nearly a decade, I can tell you Congress is not going to convert the R&D tax credit to a refundable tax credit.#OECDTaxConference

With the P2 being delayed in the EU and US, let’s take the extra time to get it right instead of doing it fast, says Wolski #OECDTaxConference

It's "extraordinarily clear" that the GILTI regime is a qualified IIR under the pillar 2 GLOBE rules, says @ItaiGrinberg, who points to European officials' affirmations (including Kreienbaum)