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Project Mint Google's Refreshing Approach to
Global Mobility Compliance
Carolina Ellerker, Global Tax Compliance Manager, Google
Amanda McIntyre, Director, PwC LLP
Stacy Zhang, Stock Administration, Google
Agenda
• The team
•Where we started
• The gap
• Introducing Project Mint
• Impact
•Q&A
The Team
GEM Payroll
and mobility
PwC Employment Tax
The Team
GEM
Payroll and
mobility
PwC
ET
● Compliance ● Systems ● Education
● Monthly filings ● Annual filings ● Equity filings
● Employment tax in APAC, EMEA, NORAM and LATAM
● ShareTax ● Equity consulting ● myTransfer
Where we started
Google’s equity
Broad based equity plan
Specifics
Mobility tracking
Global
Plan offered to ALL full time employees
Approx 70,000
We have monthly RSU Vestings, a quarterly Trading Window and some stock options still
outstanding
Equity offered in over 60 countries
3,500 annual employee moves per year, of which 95%
are permanent transfers.
Approximately 20% of employees are
mobile!
Our mobile population
US$168M equity income
sourced to more than one
location in 2016
173,569
calculations processed in
2016 99.7%
calculations are
automated
60 countries and 37 States
Tax assistance for perm
transfers only provided for
1 year
Our annual compliance review
Advisers provide updates
Review
Communicate
Implement
We work with outside advisers to understand changes in rules and regulations globally. For mobility we partner with PwC
We review the information provided once a year and also ad hoc when legislation or positions change.
If the change will impact employees, we design a communication plan to ensure they are informed. Close partnership with Global Payroll.
Changes are implemented in ShareTax, Payroll and the broker if required.
The gap
Multiple Resources - data, data everywhere
Equity Planner : local rules
Adviser’s newsletters : change in rules
PwC : weekly updates
Baker Mckenzie : bi-weekly calls
Solium : Tax guides and compliance module
Payroll advisers and PSPs
Employment Tax
In house expertise
GEO Updates
Knowledge is like paint, it does no good until it is applied
Feedback from our Stakeholders...
● Files are confusing and different between local employees and mobile employees
● Process to be followed for mobile employees is different
● Rules are confusing ● Conflicting advice- what should we do? ● What is the risk tolerance?! ● Help and support please!!
Employees
Payroll, employment tax and PSPs (payroll service providers)
● RSUs are great but taxes are complicated!
● Help us understand what are our obligations as a result of our equity.
● Moving impacts equity - I am confused!
● What happens when I sell my shares?
The result - our super villains They were spending too much time with Stakeholders and Employees
• Increased risk of audits on a personal and company level.
• Countries where reporting is not occurring on a monthly basis can create challenges.
• Feedback from stakeholders (complexity & uncertainty).
• Assumptions made when calculations were automated.
• Disconnected PSP’s unclear about complexity of mobile equity reporting requirements
Captain Complexity
Dr. Disconnected
Universala Uncertainty
Superheros Needed - The Challenge:
We had the data but…
● It was not being utilized (too many data sources, which were not always consistent)
● Timing of information delivery/availability fell short
● Noise in the system ● Outdated processes and
assumptions designed years prior
We needed help...
Introducing Project Mint
Where do I begin?
Set clear objectives 1. Have the right information at hand to be a
trusted adviser for all business partners in relation to equity tax treatment around the world.
2. Collect the most relevant and reliable information - for Google and for the employees including specific country details
3. Make it accessible and useful to the teams in the appropriate deliverables
4. Audit equity payroll filings to ensure the correct rules have been applied
Approach
1. Planning of information needed at both employer and employee level
and compile comprehensive set of questions.
a. employer requirements
i. monthly
ii. annually
iii. equity specific
b. employee requirements
i. report of equity on annual returns
ii. tax of capital gains
2. Initial input info followed by centralization of details provided by tax
advisers.
3. Collecting information from tax adviser and partners obtaining
clarification on the more complex scenarios (determined future and
current usability)
4. Regional calls to understand local rules
Countries under review
Questions
Questions
Impact
i. Employees
Determining Factors
Parameters to determine approach and cadence for employee education
• Country filing complexity - additional filings outside annual;
• Inbound and outbound reporting variances especially vis a vis what is to be reported through payroll;
• Tax impact of corporate actions (Alphabet conversion and Class C)
• Number of Employees in the country
• Noise via tickets (GUTs) and misc threads
New strategy
• Timeline for most impactful communication
• Education calendar
• Modularized education presentations
• Presentations via GVC v. in person
• Office Hours for Q&A
• Consistent messaging & delivery
• Revamped digital resources
o myTransfer
o Video - equity on the move
o gMobility website
Education Calendar
myTransfer
myTransfer
Making Equity Simple Easy to Understand & Targeted Messaging
Modularized : Live & On Demand
Stock Statements
ii. Employer
Annual filings
• Comprehensive review of the annual tax equity filing process that
has been followed in prior years.
• Redesigned the process followed in 60 countries by collaborating
with the employment tax team, payroll and vendors to ensure the
appropriate amounts are included in the country year end filings.
Identified any gaps in compliance reporting during review and
implemented changes to fix these problems.
• Annual filing calendar
• Education to local payrolls regarding country specific
rules
Knowledge sharing
The deliverables from Project Mint included clear and
concise information in relation to the employee and
employer compliance requirements. As a result:
• Members of our team gained the knowledge to
respond to employee queries more promptly and
accurately;
• We could provide the business with information that
would be relevant to making strategic decisions;
• Empower the mobility and payroll teams with
knowledge to respond to employee and business
queries.
Global Mobility
We were able to work together with the global
mobility team regarding some of the complex
rules around the world - for example:
• Brazil - additional support to inbound
employees
• Australia- deemed disposition rules
• Canada
• Denmark- issues for outbounds
• Italy
The Project
Impact for GEM and
payroll team
Impact for employees
Objectives
Gather information
Analyse and centralise
Prepare deliverables
Share
Train
Update and Iterate
Recap...
Thank You
Carolina Ellerker Google
Amanda McIntyre PwC
Stacy Zhang Google
Thank You Thank you for attending GEO’s 18th Annual Conference in Rome. We hope you enjoyed this session.
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