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GILTI Conscience Podcast | Navigating Permanent Establishments in International Tax Law [Video]

Our latest episode of “GILTI Conscience” features an in-depth discussion on the complexities of profit attribution to permanent establishments (PEs) under international tax law. Skadden’s Nate Carden, David Farhat and Stefane...more

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

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 | 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 | 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

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

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

"New Regulations Address Outbound Transfers and Transfer Pricing"

On September 14, 2015, the Internal Revenue Service (the IRS) and Treasury Department proposed new regulations addressing the tax treatment under Section 367 of the Internal Revenue Code (the Code) of certain transfers by...more

"Appeals Court Reverses IRS-Favorable Tax Court Decision in BMC Software"

On March 13, 2015, the U.S. Court of Appeals for the Fifth Circuit unanimously reversed a U.S. Tax Court decision, finding that an account receivable created to implement a transfer pricing adjustment did not constitute...more

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