GILTI Conscience

GILTI Conscience

This is GILTI Conscience: Casual Discussions on Transfer Pricing, Tax Treaties, and Related Topics, a podcast from Skadden that invites thought leaders and industry experts to discuss pressing transfer pricing issues, international tax reform efforts, and tax administration trends. We also dig into the innovative approaches companies are using to navigate the international tax environment and address the obligation everyone loves to hate. If you like what you’re hearing, be sure to subscribe in your favorite podcast app so you don’t miss any future conversations. Skadden's tax team is recognized globally for providing clients with creative and innovative solutions to their most pressing transactional, planning, and controversy challenges. Additional information about Skadden can be found at skadden.com. GILTI Conscience is a podcast by Skadden, Arps, Slate, Meagher & Flom LLP, and Affiliates. Skadden’s tax team is recognized globally for providing clients with creative and innovative solutions to their most pressing transactional, planning, and controversy challenges. This podcast is provided for educational and informational purposes only and is not intended and should not be construed as legal advice. This podcast is considered advertising under applicable state laws.

Episodes

January 4, 2024 35 mins

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...

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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...

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October 31, 2023 34 mins

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...

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October 3, 2023 38 mins

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...

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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 ...

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July 24, 2023 30 mins

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...

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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...

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June 20, 2023 34 mins

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...

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After a slow start, the Pillar Two initiative has gained momentum across the globe.“GILTI Conscience” hosts David Farhat, Nate Carden, Stefane Victor and Eman Cuyler spoke with Vikram Chand, a professor at the University of Lausanne, to discuss the latest Pillar Two developments and implications for international taxation.

The conversation delves into the widespread adoption of Pillar Two, including in Europe, Asia and low-tax juris...

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Though many opportunities exist for students interested in a career in tax law, there has been no clear environment for cultivating talent in the area of transfer pricing. Now, an ABA program offers up-and-coming professionals the opportunity to learn directly from leaders in this niche field.  

Launched in the midst of the pandemic in 2020, “Transfer Pricing: From Classroom to Boardroom” (TP C2B) seeks to provide students...

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In this episode of GILTI Conscience, Skadden’s Nate Carden, David Farhat and Stefane Victor continue the podcast’s spotlight series with tax associate Katy Stone, who discusses the impact tax-related pro bono work has had not only on the lives of other but also on her career.

Katy describes how pro bono matters — which she was introduced to early — frequently have a deeply human element and providing tax assistance often has a tangi...

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In the second of this two-part GILTI Conscience series, our Skadden tax attorneys continue their conversation with Lolade Ososami, a partner and head of the tax team at Udo Udoma & Belo-Osagie, and Zach Pouga, a partner in the International Tax Group at Ernst & Young, on the myriad tax issues faced by Africa-based companies, companies with a presence in Africa and those doing business on the continent.

Among other topics, th...

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Conversations surrounding transfer pricing practices rarely span to include the myriad regulations throughout Africa. However, across the continent, there are vast distinctions between countries that are thriving under new international tax rules and others that are struggling to keep up. 

Lolade Ososami, a partner and head of the tax team at Udo Udoma & Belo-Osagie, says that transfer pricing has grown and evolved in Afric...

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November 30, 2022 31 mins

In an effort to address tax issues surrounding the ever-growing digitalization of the global economy, the OECD proposed blueprint plans called Pillar One and Pillar Two. Though they were introduced  in October 2020, implementation remains a challenge. 

In this episode of the GILTI Conscience podcast, Europe tax head James Anderson and London tax partner Alex Jupp join our hosts to discuss how the U.K. may be the first out ...

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For many low-income individuals,  filing taxes may be a daunting task, and many may even choose to avoid interacting with the IRS altogether due to negative experiences. However, not filing taxes may mean missing out on crucial refunds and benefits.. 

From low-income taxpayer clinics in communities to organizations and initiatives such as VITA, GetYourRefund and Code For America, there are a multitude of pro bono opportuni...

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The OECD transfer pricing guidelines include DEMPE — the development, enhancement, maintenance, protection and exploitation of intangibles — as part of their efforts to deal with the legal status of both IP and economic ownership. Originally, the regulations stated that only legal ownership existed; DEMPE was incorporated to accommodate contributions made by entities other than the legal owner. 

But how dependable and comprehen...

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In this episode of the “GILTI Conscience” podcast, Roger Brown, global head of Tax Strategy at Chainalysis, joins our hosts Nate Carden and David Farhat to talk about the basics of blockchain. Roger explains what blockchain is, how tax rules apply to crypto and the field’s potential benefits.

Roger says that people regularly approach him with questions about blockchain and crypto — although the sector began forming many years ago, s...

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In this episode of the “GILTI Conscience” podcast, longtime Skadden tax partner Fred Goldberg joins our hosts Nate Carden and David Farhat to discuss his one-of-a-kind journey through the public and private tax sectors. Fred details the changes he’s seen, his hopes for the future of the field and his advice for those looking to begin a career in tax law.

As Fred notes, the tax system is the one set of regulations that every individu...

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In this episode of the “GILTI Conscience” podcast, Bram Isgur, principal at Keystone Strategy, joins our hosts Nate Carden and David Farhat to talk about transfer pricing on an ex ante and ex post basis. They discuss the use cases for each method, how these methods differ across industries and why it’s important to think about the bigger picture in preparing for unimaginable events and changes. 

So, should you take an ex ante a...

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In this episode of the “GILTI Conscience” podcast, Kroll directors Ryan Lange and Kerim Keser and Skadden partner Johannes Frey join our hosts Nate Carden and David Farhat to explore the details of the German nonresident IP withholding tax. They discuss taxation questions that are still up in the air, how the rule could affect multinational corporations, the valuation of intellectual property (IP) registration and the best steps to...

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