The OECD’s January 2026 Administrative Guidance on Pillar Two introduces new safe harbor provisions that could significantly affect how US multinationals are taxed globally. This episode breaks down the key provisions and their accounting and financial reporting implications.

In this episode, we discuss:

• 1:13 – Background on Pillar Two and core concepts
• 6:57 – Overview of the OECD Administrative Guidance
• 17:10 – Criteria for the Side-by-Side Safe Harbor
• 21:46 – Ultimate Parent Entity Safe Harbor overview
• 25:25 – Key accounting and financial reporting considerations
• 33:21 – Extension of the Country-by-Country Safe Harbor
• 35:15 – Final reminders and key takeaways

For more information on accounting for Pillar Two, read our In depths, OECD Pillar Two: Time to act on the global minimum tax and Accounting for Pillar Two: Frequently asked questions. Also, check out our Income taxes guide for additional background on existing guidance.

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About our guests

Pat Brown is PwC’s National Tax Office Co-Leader. Prior to joining PwC, he spent 16 years in the private sector, including as the director of tax policy for a Fortune 50 company. Pat has also served in the US Treasury’s Office of Tax Policy as an attorney-advisor and as Associate International Tax Counsel.

Jennifer Spang is PwC’s National Office income tax accounting leader, specializing in tax accounting under US GAAP and IFRS. She has over 30 years of experience helping companies in a variety of industries navigate complex tax accounting matters.

About our guest host

Kyle Moffatt is PwC’s Professional Practice leader, leading a team responsible for working with standard setters and regulators as well as delivering brand-defining thought leadership and educational materials. He also consults with engagement teams and audit clients on SEC reporting matters. Before PwC, Kyle spent almost 20 years with the SEC, most recently as Chief Accountant and Disclosure Program Director in the Division of Corporation Finance.

Transcripts available upon request for individuals who may need a disability-related accommodation. Please send requests to us_podcast@pwc.com

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The US public policy landscape continues to evolve and impact US and global businesses. We cover key developments in Washington, D.C., including tariffs, AI, and other areas as well as at the SEC and PCAOB, along with what it all means for financial reporting and strategic decision-making.

In this episode, we discuss:

• 1:04 – Overview of the 2026 public policy environment and business implications
• 4:17 – Affordability challenges and limits of policy solutions
• 9:35 – Tariff strategy shifts and ongoing uncertainty for businesses
• 13:43 – SEC and PCAOB priorities and leadership changes
• 27:51 – INVEST Act and the outlook for capital formation
• 31:06 – AI governance and the fragmented state and federal approach
• 36:48 – Key takeaways and what businesses should monitor in 2026

For more on tariffs, listen to our recent episode, Tariff uncertainty: Business and financial reporting impacts. Be sure to follow this podcast on your favorite podcast app and subscribe to our weekly newsletter to stay in the loop.

About our guests

Roz Brooks is PwC's US Public Policy Leader. Roz is responsible for ensuring PwC has a voice in important debates at the nexus of business and government and helping the firm successfully execute its business strategy. Roz leads PwC’s engagement with Congress, the White House, regulatory agencies, state and local governments, and organizations including trade associations, think tanks, and NGOs.

Michael O’Brien is a PwC Director in the Office of Government, Regulatory Affairs & Public Policy. Michael represents the firm and its interests before Congress, the Executive Branch and federal regulatory agencies. He has advocated on the firm's behalf on matters including the implementation of Sarbanes-Oxley and Dodd-Frank, state and federal taxation matters, IFRS, litigation reform, and the competitiveness of the U.S. capital markets. Besides assisting in general lobbying activities, Michael has researched and developed periodic political analyses and strategies for firm distribution.

About our guest host

Kyle Moffatt is PwC’s Professional Practice leader, leading a team responsible for working with standard setters and regulators as well as delivering brand-defining thought leadership and educational materials. He also consults with engagement teams and audit clients on SEC reporting matters. Before PwC, Kyle spent almost 20 years with the SEC, most recently as Chief Accountant and Disclosure Program Director in the Division of Corporation Finance.

Transcripts available upon request for individuals who may need a disability-related accommodation. Please send requests to us_podcast@pwc.com.

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ASU 2025-07, Derivatives Scope Refinements and Scope Clarification for Share-Based Noncash Consideration from a Customer in a Revenue Contract, is new FASB guidance that adds a derivative scope exception and clarifies the boundary between revenue and financial instruments guidance for share-based non-cash consideration from customers.

In this episode, we discuss:

• 2:39 – New derivative scope exception for contracts tied to operations
• 11:05 – Applying revenue versus financial instruments guidance
• 14:55 – Examples illustrating application of the share-based consideration guidance
• 22:59 – Effective date, transition, and adoption considerations

For more information, read our In depth, FASB issues new standard on derivative and revenue scoping and check out chapter 3 of our Derivatives and hedging guide.

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About our guest

Bret Dooley is a PwC National Office Deputy Chief Accountant who leads teams focused on the financial services sectors and accounting for financial instruments. He has over 25 years of experience in the financial services, banking, and capital markets industries. Bret focuses on emerging financial reporting issues related to financial instruments, developing interpretive guidance, and assisting clients in resolving complex accounting matters.

Angela Fergason is a partner and standard setting leader in PwC's National Office who specializes in accounting for revenue and employee compensation arrangements. She also consults on a range of financial reporting issues impacting technology companies.

About our guest host

Diana Stoltzfus is a partner in PwC’s National Office who helps to shape PwC’s perspectives on regulatory matters, responses to rulemakings and policy development, and implementation related to significant new rules and regulations. Prior to rejoining PwC, Diana was the Deputy Chief Accountant in the Office of the Chief Accountant (OCA) at the SEC where she led the activities of the OCA’s Professional Practices Group.

Transcripts available upon request for individuals who may need a disability-related accommodation. Please send requests to us_podcast@pwc.com

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