GILTI Conscience

This podcast’s title hasn’t changed, but on the international tax stage GILTI is converting to the new CFC-tested income (NCTI) regime.That’s just one shift brought about by the One Big Beautiful Bill that Congress passed on July 4. Skadden colleagues Loren Ponds, Eric Sensenbrenner and Paul Oosterhuis break down the bill’s implications in this conversation with David Farhat and Stefane Victor. The panel explores the legislative pr...

The stakes are high. That’s how Skadden national security partner Brooks Allen sets the stage for the U.S. Supreme Court case surrounding President Trump’s tariff policy. And that case is just one dynamic in today’s  “revolutionary” tariff environment. Brooks joins Skadden tax partner Jonathan Welbel and Ryan principal Rodrigo Fernandez to break down key issues affecting tariffs and transfer pricing. Hosts David Farhat and Ste...

For tax authorities and even taxpayers, AI promises to make lives easier. At the same time, it carries risks that “cannot be taken out of the system.” Dr. Stephen Daly, reader in tax law at King's College London, describes this dynamic in a conversation with Skadden partners David Farhat and Eric Sensenbrenner, associate Stefane Victor and senior advisor De Lon Harris. The panel explores the best and worst of the impact of AI in th...

Changes in the luxury fashion industry are reshaping transfer pricing considerations, says Giuseppe Abatista vice president at Banca Popolare di Puglia e Basilicata. In this conversation with Skadden tax partner David Farhat and associate Stefane Victor, Giuseppe shares his insights about how price increases, supply chain centralization and tariff uncertainties are creating new transfer pricing complexities in an industry known for...

Machado Meyer tax partner Fernando Colucci joins Skadden’s David Farhat, Loren Ponds, Eman Cuyler and Stefane Victor to explore Brazil's historic shift from a 27-year formulaic transfer pricing system to full OECD compliance. As he explains, “We moved from a very strict, very formulaic approach to a simple, a direct import of the arm's-length principle.” Tune in for his insights on dramatic changes facing multinational enterprises ...

When goods, services and rights go back and forth within a company, how do you attribute profit or loss to one part of the company versus another? Former OECD head of tax treaties and transfer pricing Mary Bennett and EY’s Mike McDonald join this episode of “GILTI Conscience” for a detailed discussion on the attribution of profits to permanent establishments. Skadden tax partners David Farhat and Nate Carden and associate Stefane V...

Amount B is designed to streamline transfer pricing for baseline distribution and marketing companies worldwide, but “we’re apparently in a world of complexity and controversy,” says Jessie Coleman..

A principal at KPMG, Jessie joins Skadden attorneys Nate Carden, David Farhat, Eman Cuyler and Stefane Victor to discuss everything there is to know about the current and future status of Amount B. Together, they explore questions of sc...

In our second episode in our spotlight series focused on celebrating diversity, GILTI Conscience’s David Farhat and Stefane Victor are joined by colleagues Brian Breheny and Jordan Schwartz for an earnest dialogue on DEI in big law. The guests discuss some of the challenges they faced as gay professionals, including their experiences coming out at work and questions they faced, as well as their efforts to advocate for diversity in ...

“You want people to be themselves. You're going to get the most productivity, the most career longevity from somebody that's happy about being where they are,” says De Lon Harris. 

In celebration of Pride Month, Skadden tax senior advisor De Lon Harris joins Eman Cuyler and Stefane Victor on “GILTI Conscience,” where he discusses his life and career as a gay professional. De Lon talks about his 30-plus years at the IRS and the ...

“Transfer pricing, itself, is more of an art than a science. There's a lot of gray area in many, many aspects of transfer pricing,” says Clark Armitage. 

In this episode of the “GILTI Conscience” podcast, Skadden attorneys Nate Carden, David Farhat, Eman Cuyler and Stefane Victor, are joined by guest Clark Armitage of Caplin & Drysdale. The group dives into a comprehensive discussion about the intricacies of ICAP, MAP and A...

In this episode of the “GILTI Conscience” podcast, Skadden attorneys Eman Cuyler and Stefane Victor are joined by Jessica Hough, tax partner and head of Skadden’s Washington, D.C. office, and Pam Olson, a tax policy consultant at PwC, both of whom have significant experience advising on issues related to tax policy.

Tune in to this special episode in which two very distinguished women leaders within the tax community share their ins...

On this episode of the “GILTI Conscience” podcast, Skadden attorneys David Farhat, Nate Carden, Eman Cuyler and Stefane Victor, are joined by colleagues Fred Goldberg and De Lon Harris, both of whom have had distinguished careers with the IRS.  

Tune in to hear Fred and De Lon share their thoughts, insights and predictions on the latest IRS projects and initiatives, as they talk about what's going on at the agency, new fun...

The evolving landscape of tax reforms in Japan and the broader Asia Pacific region presents a complex tapestry of challenges and strategic shifts.

On this episode of the “GILTI Conscience” podcast, Skadden partners Nate Carden and David Farhat are joined by Samuel Gordon, an international tax partner at Deloitte in Japan to dissect tax implications, reform and concerns in this part of the globe.

The discussion delves into the viewpoi...

While tax insurance can be used in a variety of contexts, from M&A deals to regular tax planning scenarios, it is also relevant when it comes to transfer pricing. Recent developments have expanded the scope of tax insurance to cover multiple years of transfer pricing in returns in M&A deals, and the potential of seeing more transfer pricing insurance in the future is a strong possibility.

On this episode of the “GILTI Consci...

Pillar Two is no longer hypothetical. It’s now time for Pillar Two “readiness.”

In this episode of the “GILTI Conscience” podcast, hosts David Farhat, Nate Carden, Eman Cuyler and Stefane Victor discuss Pillar Two with Eric Sensenbrenner and Paul Oosterhuis. The group delves into the current state of Pillar Two, which has shifted from a source of concern to a challenge being actively addressed. Companies will have to remain nimble a...

Pro bono projects provide unique flexibility and opportunities for skill development, benefiting both the professional who takes on the work and the client. 

In this episode of “GILTI Conscience,” hosts David Farhat, Stefane Victor and Nate Carden present the next installment of the podcast’s Spotlight Series, which includes a discussion with associates Jared Binstock and Sanessa Griffiths about the role pro bono work plays in ...

In this episode of the “GILTI Conscience” podcast, David Farhat, Nate Carden and Stefane Victor are joined by Mike Gaffney of Atlantic Global Risk to talk about tax insurance and its role in addressing uncertainty in tax laws. 

Mike describes the workings of tax insurance, including the length of a typical policy, particularly surrounding a deal, and explored ideas such as deciding what covered tax position to insure and how va...

In this episode of the “GILTI Conscience” podcast, hosts David Farhat and Nate Carden are joined by associates Stefane Victor and Eman Cuyler, and Howard Sacarob, head of U.S. tax for the Royal Bank of Canada (RBC). Mr. Sacarob is also a member of RBC’s diversity leadership council and an executive sponsor of the Pride Employee Resource Group (ERG) at RBC, where he works to make diversity and inclusion central to the firm’s culture...

In this episode of the “GILTI Conscience” podcast, Skadden partners David Farhat and Nate Carden, along with associates Eman Cuyler and Stefane Victor, discuss Pillar One’s Amount B with Jessie Coleman of KPMG.

In December 2022, the OECD issued documentation providing a much anticipated outline of Amount B, however, many uncertainties still remain surrounding scoping requirements and pricing.There is still much work to be done to ad...