Steve Kohart
New York City-based international tax partner at PwC and former advisor to the OECD’s Center for Tax Policy and Administration, providing expertise on Pillar Two rules and the simplified ETR safe harbor.
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Mar 9, 2026 • 39min
Pillar Two SESHion: ‘Simplified’ safe harbour
Steve Kohart, a New York City-based international tax partner at PwC and former OECD advisor, breaks down the permanent simplified ETR safe harbor and its transitional bridge from CBCR. They cover the January side-by-side agreement, denominator and numerator adjustments, deferred tax challenges, JV and M&A complications, transition rules, excess negative taxes, and practical compliance priorities.
