Companies Aiming to Bring IP to the US Have a Pillar Two Problem

Companies are clamoring to bring their valuable intellectual property back to the US, as expanded tax benefits and the new side-by-side global tax system make repatriating suddenly more attractive, tax professionals said Wednesday. But there’s a problem.

The type of reorganization companies want to make to avoid exit charges as they move IP out of foreign countries — so called GloBE reorganizations — are essentially impossible to get done for many companies, Wade Sutton, international tax leader at PwC’s Washington National Tax Services, said at a Practising Law Institute event.

A GloBE reorganization lets a company transfer an asset and ...