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I already have certificates in accounting, worked in Accounting at the US Attorney's office here when I was a teenager, did payroll at one Law Firm, was a Store Manager, Assistant Store Manager, handle the affairs of my eldest son, help my mother and do so very much already. I did not take any bribes while running for Congress twice as well as City Council and am a Committeewoman. I was also on the Judicial and US Presidential ballot before, and do not have a criminal record.

I initially thought if you pass any of the 3 safe harbors you should ideally should be relieved from the QDMTT as well in any shape or form, i am now trying to understand what is a QDMTT safe harbor isnt it the same? However, i am still not able to understand if lets say you pass the safe harbor but then the Q CBCR report is a US GAAP based Report (10K) then its not apples for apples because you would ideally have calculated a QDMTT based on local stat and not US GAAP?

Hey Doug, I used to watch your videos back in 2017 when I was in a very dark place. My work was not going well, my personal life was in shambles..the problem at work was one negative rat was gossiping about me to everyone so I felt quiet unwelcomed at work at one point..when people saw me they were like "ugh its him"..all your points are excellent and to those points I would like to add, have a bit of life outside of work. I bought a cheap 2nd hand hatchback and solo drove all around victoria in Australia. I helped out at the local temple serving free food to anyone who'd come there...as a human we need to feel good about ourselves! I used the positivity i garnered from these activities outside work to fuel my enthusiasm at work and turned things around :) Eventually i ended up leaving that big 4 firm and got into a managerial role in the industry and ended up hiring the same team ...from the same big 4 😂...

Great video. I'm going through this now at 47. I shaved my head as well, but it seems impossible to get rid of the shadow around the spots.😮

glad to be on your podcast Doug!

As a black attorney looking to break into tax, I found this interview to be extremely insightful. 🙏🏾

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Should I be worried getting my job replaced ?

Jessie B. Karla

circular 1055

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2017 was 7 years ago? Time flys!

Thank you for this segment, Doug & Giorgia. I conclude that there is an important relationship between Pillar 1 and Pillar 2. I view Pillar 1 (Pil 1A and Pil 1B) as a pre-step to getting to an accurate and fair Pillar two top-up tax calculation by jurisdictions. And, who says accuracy in law interpretation and application, and in tax accounting calculation, says client value (i.e. low to no audit risks). In this new era, when handling a Pillar two project, I would do the following: A. If for example, I am dealing with the "P2 Top-up tax calculation exercise" for an MNE group of the specific type of MNE group(s) that are keenly targeted and thereby concerned by the many, if not all, of the "Taxation of The Digital Economy" report(s) and important discussion(s) and consensus that have either been published, discussed, or agreed upon, I would do the following: 1.a Identify & confirm the MNE type being dealt with. Confirming whether Pillar 1 implications exist. One does so by: 1.b. Analysing the F/S B/S & P&L for types of assets held and types of intraMNE group income and payments. 1.c. Requesting, obtaining, analysing, and understanding the identity of legal, beneficial, and tax owners of major IP. 1.d. Analysing, understanding, and tracing intraMNE cross border payments and revenues related to the major IPs of the MNE (see point 1.b above) to their respective final market jurisdiction (jurisdiction of final third party client). 2. Related to point 1.c above, properly re-allocating IP payment deduction expenses from jurisdiction of intraMNE recipient member to jurisdiction of third party (market based jurisdiction). 3. Determining whether the new approach to global revenue distribution and its taxation (new taxing rights to market based jur) is important enough to intentionally create substance in those new jurisdiction(s). 4. We have assumed that the newly determined allocation of revenues under pillar 1a impacts the said MNE group. Therefore, changes in the revenue and expense reporting for financial statements' P&L reporting purposes driven by agreed-upon market based approach may significantly (revenues especially for groups with regional distributing entities) affect the transfer pricing reporting of the MNE group on an onward basis. This, not only impacts the third party revenues and exp correlated to those intraMNE group IP-related revenues and payments transfers; but it also importantly impacts the FIN 48 (and their non-US equivalent) position and disclosure of the group. Thereby, impacting the final amount of covered taxes allowable under Pillar two calculation. Additionally, the deferred tax accounting impact of the non-pillar-two-adhering FIN 48 tax should be analysed and addressed. That is: adhering to these new regulations ensures greater comfort with the intraMNE and 3rd cross border revenues and allocated expenses reported to each jurisdiction. 5. As such, if involved on a pillar two project of an MNE group deemed both "in-scope" and to be digital company (IP-heavy and internet-based heavy servicing company), it is important to ensure that pillar one regulation, as it relates to revenue and expense reporting and allocation, has been followed. In our case, confirming that amount A's formula was applied when allocating intraMNE cross border revenues and payments (applying same to related third party revenues and expenses).

Dude, you are so very handsome! Hair or no hair, both look good on you ❤ I'm a 35 yo female who just got it recently and I'm so terrified. Already struggling with facial features which I was always able to hide behind the hair pretty well, but now going bold lol just gonna be one extra ugly middle aged woman I guess 😅

Pat just exercises so he looks good on TV (or what passes for TV nowadays!)🤣

US needs to move to residency based taxation. The IRS can’t manage an extraterritorial tax system

Thanks for sharing. Had Alopecia for 30 years, I'm at the point now that I have to shave my head, which is a daunting. Thanks for the positivity in this video. 👍

He gave great advice! Good episode!

How often do you shave your head?😊😊😊

Love this Doug!

Good content

Did you like Florida or St. Louis camp better?

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Mmmm😊😊😊.

Pro-level

I didn't know most people Hate Tax, like what's wrong with them? I love Tax but unfortunately I'm finding it hard to switch from Audit😢

hey Doug, you are doing a great job, how to contact you ?

Hi Doug, could you turn on the subtitles, please 😊

You have been warned before about posting your garbage videos on the internet. Now you will face the consequences.

Tax Attorney look in the Legal Side, Accountant look into Numbers.....

Mr. Yamaguchi's explanation on Japanese slow, vague, yet very complicated registration process is excellently done.

Great content!

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Love the "niche paradox" and that you see yourself as a "business enabler".

Te enseño español cuando quieras 😂

💖 "PromoSM"!

Quite insightful

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The podcast is about a completely different topic

Hi Doug ! Watched your vlog back then when I was a student to get some career & life tips. Did not know anything around transfer pricing or International tax. I'm TP senior consultant in Big 4 now, time flies. Thank you, the podcast was great as usual !!

I love the format of discussing the topic in layman terms in the examples and then providing the cites at the end to the code and regs.

I'm 40, male. One day, just a week before my 40th birthday (3 mo. ago), my wife noticed I've got a bald patch on the top of my head, about 2-3 cm (~ an inch) diameter. The next day she found an another small patch on my head (behind the ear). Got scared a bit 'cause I always had very dense, black and strong hair... Long story short - I went to the dermatologist, got diagnosed with alopecia areata, I'm physically sane (I ran blood tests, inc. thyroid, inflamations etc. that doctor told me to do), I tried prescribed corticosteroids ointments but - to be honest - no significant improvement... Since then a lot of new patches has appeared and old ones has got bigger (up to ~10 cm diameter - ~ 3,5 inches). I'm just fricking tired with wearing baseball hat all day long and "spreading" my hair all around me (yuck). Eventhough I still have longer hair, so patches are not that much visible but they are anyway - every day more and more... I'm going to shave the head completely this week. Thank you for this video - it gave me the courage to to it. Best regards and cheers from Poland!

Really fun discussion Doug, thanks!

Very good video 💖

Nice video 💖💖💖

how old do you have to be to participate in the cardinals fantasy camp

Something fishy is being done by someone from the authorities.

Ensure Transparency please

Mlso shoutout new friend here

Good