Jeffery G. Mitchell is a Senior Adviser with the Centre for Tax Policy and Administration directorate of the Organisation for Economic Cooperation and Development (OECD) in Paris, France. Since joining the OECD in 2019. Jeff has provided policy and technical advice on the OECD/G20 project on the Digitalisation of the Economy, focusing on Pillar Two. Prior to joining the OECD, Jeff was a Branch Chief in the Office of Associate Chief Counsel (International), Washington, DC, where he led a team of attorneys responsible for providing guidance related to the Global Intangible Low-Taxed Income (GILTI), subpart F, Passive Foreign Investment Company (PFIC), and related provisions of the U.S. Internal Revenue Code. Jeff began his career with the Office of Associate Chief Counsel (Income Tax & Accounting), where he focused on issues related to accounting methods, inventories, and Uniform Capitalization. Jeff earned an LL.M. in Taxation from the University of Florida Graduate Tax Program, a J.D. from the University of Tennessee College of Law, and a B.S. in Accounting from David Lipscomb University.
The GloBE Pillar 2 model rules developed by the OECD and reflected in the recently adopted EU directive on minimum taxation will come into force on 1 January 2024. The OECD has done extensive and extremely detailed work on this topic, which has also taken into account the particularities of investment funds. As these rules are entirely new and rather complex, the speakers will guide us through the specific key points that investment fund structures will need to take into account in order to comply with these new rules, and in particular the treatment of investment funds as Excluded Entities, the consolidation provisions applicable to fund structures and how structure analysis should be approached.
Managing Director, Head of Tax Technical Team
Director
Senior Adviser
Of Counsel