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GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions [Video]

The “GILTI Conscience” podcast team, led by partners David Farhat and Nate Carden, hosted Clark Armitage of Caplin & Drysdale for an in-depth conversation on the various methods for resolving cross-border transfer pricing...more

GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials [Video]

Tax of counsel Fred Goldberg and senior advisor for tax resolution strategies De Lon Harris, both formerly of the IRS, joined the hosts of “GILTI Conscience” for a comprehensive look at current developments at the agency,...more

GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint [Video]

Our latest “GILTI Conscience” podcast featured Deloitte international tax partner Sam Gordon, who joined hosts Nate Carden and David Farhat for an in-depth look at Asia Pacific’s perspective on Pillar Two, particularly from...more

GILTI Conscience Podcast | Gearing Up for Pillar Two [Video]

Our “GILTI Conscience” team was joined by colleagues Paul Oosterhuis and Eric Sensenbrenner to discuss what companies can expect now that Pillar Two implementation is becoming a reality. ...more

GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good  [Video]

In our third installment of the “GILTI Conscience” pro bono spotlight series, counsel Jared Binstock and associate Sanessa Griffiths joined the podcast hosts to discuss how they’ve utilized their corporate tax backgrounds to...more

GILTI Conscience Podcast | Tax Insurance 101 [Audio]

Atlantic Global Risk director Mike Gaffney joined our “GILTI Conscience” podcast for an in-depth discussion with David Farhat, Nate Carden and Stefane Victor on tax insurance, including how the product works, how policies are...more

GILTI Conscience Podcast | Spotlight Series: An Evolution of Workplace Diversity and Acceptance [Audio]

Howard Sacarob, head of U.S. tax at Royal Bank of Canada and executive sponsor of RBC’s PRIDE employee resource group, joined Nate Carden, David Farhat and our “GILTI Conscience” team to discuss the importance of allyship in...more

GILTI Conscience Podcast | Amount B Back in the Spotlight [Audio]

Following the OECD’s long-awaited guidance that was issued in December 2022, Pillar One’s Amount B has begun receiving renewed attention. Jessie Coleman, transfer pricing principal with KPMG, joined the “GILTI Conscience”...more

6/20/2023  /  GILTI tax , New Guidance , OECD

IRS Issues Interim Guidance to Staff on Reviewing and Accepting Advance Pricing Agreement Submissions

The Internal Revenue Service (IRS) recently released instructions for employees that may have the effect of deterring some companies from submitting advance pricing agreement (APA) requests. That, in turn, could introduce...more

GILTI Conscience Podcast | Spotlight Series: Beyond the Technical Side of Tax Law [Audio]

In the second installment of the “GILTI Conscience” pro bono spotlight series, Palo Alto associate Katy Stone delves into how she has used her corporate tax knowledge to tap into the often overlooked emotional side of tax...more

3/14/2023  /  Corporate Taxes , GILTI tax , Pro Bono

GILTI Conscience Podcast | An In-Depth Look at International Tax in Africa: Part 1 [Audio]

In the first of a two-part “GILTI Conscience” series, we detail transfer pricing across the African continent, as well as taxation in the region generally. Skadden partners Nate Carden and David Farhat and associates Mayté...more

1/18/2023  /  Africa , Tax Planning , Transfer Pricing

GILTI Conscience Podcast | Spotlight Series: Pro Bono Opportunities in the Tax World  [Audio]

The latest episode of Skadden’s “GILTI Conscience” podcast spotlights how, despite perceptions to the contrary, tax attorneys have a wealth of opportunities to do pro bono work focused on their area of law. Hosts Nate Carden,...more

GILTI Conscience Podcast | Talking Transfer Pricing and the Arm’s Length Principle With Mike McDonald [Audio]

In the new episode of our tax podcast, “GILTI Conscience,” EY’s Michael McDonald discusses whether the OECD’s DEMPE transfer pricing guidelines are being properly interpreted, including whether some jurisdictions are placing...more

GILTI Conscience Podcast | Blockchain for Beginners: Basic Tax Issues for Digital Assets [Audio]

In the new episode of our tax podcast, “GILTI Conscience,” hosts Nate Carden, David Farhat and Stefane Victor discuss taxation issues for digital assets such as bitcoin and stable coins with Roger Brown, the global head of...more

Tax Legend Fred Goldberg Shares Insights From His 50 Years in Tax Law [Audio]

In the new episode of our tax podcast, “GILTI Conscience,” Fred Goldberg shares insights from his illustrious five-decade career in tax law, from his time as a junior associate through his service as the commissioner of the...more

The Issue Behind 'Almost All' Transfer Pricing Cases: Ex Ante or Ex Post Basis [Audio]

In episode seven of "GILTI Conscience," hosts Nate Carden and David Farhat talk with Keystone Strategy's Bram Isgur about the issue underlying most major transfer pricing cases: whether to look forward to see what pricing...more

5/18/2022  /  Multinationals , OECD , Transfer Pricing

Navigating the Once-Obscure German Nonresident Withholding Tax [Audio]

In this episode of Skadden’s “GILTI Conscience” podcast, partners Nate Carden and David Farhat discuss the German nonresident withholding tax with partner Johannes Frey, in the Frankfurt office, and Ryan Lange and Kerim Keser...more

New Regulation: Statutes, Pillars, and the Build Back Better Act [Audio]

In the new episode of our tax podcast, “GILTI Conscience,” partners Nate Carden and David Farhat speak with Skadden of counsel Paul Oosterhuis and associate Huzefa Mun about tax legislation, including how the potential...more

The Tax Legislation Process and What to Expect in 2022 [Audio]

In the new episode of Skadden's "GILTI Conscience" podcast, partners Nate Carden and David Farhat talk with about the "art" of drafting and passing tax legislation with Loren Ponds, a former tax counsel for the House of...more

Spotlight Series "The Importance of Diversity, Equity & Inclusion in Tax Law" [Audio]

In the latest episode of Skadden's tax podcast "GILTI Conscience," hosts Nate Carden and David Farhat talk with associates Eman Cuyler and Stefane Victor about Black identity and lawyering, particularly among tax...more

Arm's Length Principle Vs. Implicit Support: What's the Way Forward? [Audio]

In episode two of "GILTI Conscience," tax partners Nate Carden and David Farhat talk with economist Bram Isgur of Keystone Strategy about the transfer pricing implications for intercompany loans and guarantees. "The stakes...more

Multinationals Should Consider Adding ‘Competent Authority Processes’ to Their Tax Strategies

Takeaways - Transfer pricing uncertainly has increased with U.S. tax reforms and an OECD proposal establishing a new approach to determining the jurisdiction where income is recognized. The “competent authority...more

Musings on Multinational Tax: What to Expect From GILTI Conscience [Audio]

Skadden is proud to present "GILTI Conscience," a new podcast series in which tax partners Nate Carden and David Farhat invite other industry leaders and authorities to join them in discussing pressing transfer pricing...more

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