GILTI Conscience Podcast | The Evolution and Impact of the CWI Standard
GILTI Conscience Podcast | Navigating Pillar Two: Side-by-Side, Safe Harbors and the Future of Global Tax Cooperation
GILTI Conscience Podcast | From GILTI to NCTI: Unpacking the 2025 Tax Overhaul
Taxing Intelligence: AI's Role in Modern Tax Administration
GILTI Conscience Podcast | Navigating Permanent Establishments in International Tax Law
GILTI Conscience Podcast | Spotlight Series: A Celebration of Pride Month With IRS Veteran De Lon Harris
GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions
GILTI Conscience Podcast | Spotlight Series: A Conversation With Women Trailblazers in Tax
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint
GILTI Conscience Podcast | Gearing Up for Pillar Two
GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good
GILTI Conscience Podcast | Spotlight Series: An Evolution of Workplace Diversity and Acceptance
GILTI Conscience Podcast | Amount B Back in the Spotlight
GILTI Conscience Podcast | Update on Pillar Two: Where it Stands Today and What To Expect
GILTI Conscience Podcast | Spotlight Series: Beyond the Technical Side of Tax Law
An In-Depth Look at International Tax in Africa: Part 2
GILTI Conscience Podcast | The UK Tackles Pillars One and Two
GILTI Conscience Podcast | Spotlight Series: Pro Bono Opportunities in the Tax World
Musings on Multinational Tax: What to Expect From GILTI Conscience
On this episode of “GILTI Conscience,” Nate Carden, David Farhat, Eman Cuyler and Stefane Victor are joined by transfer pricing expert Mike McDonald for an in-depth discussion on the commensurate with income (CWI) standard....more
This article addresses certain U.S. federal income tax issues for U.S. corporations with Israeli research and development subsidiaries. It focuses on four interconnected issues that create complexity and potential tax...more
On this episode of "GILTI Conscience," Skadden attorneys David Farhat, Patrick O'Gara, Loren Ponds and Stefane Victor are joined by guest Pascal Saint-Amans, founder and CEO of Saint-Amans Global Advisory and former director...more
The Organisation for Economic Co-operation and Development (OECD) issued a side-by-side package (the package) on January 5, 2026, resolving many of the concerns that U.S.-parented multinational companies had with the Pillar...more
The Organisation for Economic Co-operation and Development (OECD) recently released its highly anticipated Side-by-Side (SbS) package, marking a significant step in alleviating the application of the global minimum tax rules...more
Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for November 25, 2025 – December 10, 2025....more
On December 4, 2025, the United States Internal Revenue Service (IRS) published Notice 2025-75, Notice 2025-77, and Notice 2025-78 providing guidance on certain provisions that were modified as a result of the H.R. 1, P.L....more
The United States Internal Revenue Service (IRS) released Notice 2025‑72 (Notice) on November 25, 2025, addressing two issues arising from the repeal of the one‑month deferral election under Section 898(c)(2). Specifically,...more
As with the Tax Cuts and Jobs Act (TCJA) in 2017, the 2025 calendar year ushered in a new set of tax legislation – the One Big Beautiful Bill Act (OBBBA) – as well as several changes the current administration made to the...more
On this episode of “GILTI Conscience,” Skadden tax attorneys David Farhat, Paul Oosterhuis, Loren Ponds, Eric Sensenbrenner and Stefane Victor break down the sweeping U.S. tax reform enacted in July 2025, with a focus on the...more
Did you just find out that as a dual citizen you have to report U.S. taxes even if you live abroad? Did you just discover you needed an FBAR, Form 5471, GILTI calculation, Form 3520, Form 5472, or other foreign reporting?...more
The One Big Beautiful Bill Act (OBBBA) is big news for closely held businesses. Signed into law on July 4, 2025, by President Trump, the massive spending and tax package made many provisions from the 2017 Tax Cuts and Jobs...more
As artificial intelligence has taken center stage across industries, does it also have a place in tax administration? Our latest episode of “GILTI Conscience” explores potential applications of AI in the world of tax,...more
Overview: The One Big Beautiful Bill Act (OBBB) renamed Global Intangible Low-Taxed Income (GILTI) to Net CFC Tested Income (NCTI), focusing on income earned by Controlled Foreign Corporations (CFCs). While the name change is...more
On July 4, 2025, the One Big Beautiful Bill Act (OBBBA) was signed into law. It is a landmark piece of legislation that introduces several important changes to the US international tax regime. This alert provides an overview...more
On July 4, 2025, President Trump signed the One Big Beautiful Bill Act (the OBBB) into law, making permanent the reduced individual tax rates and brackets established by the Tax Cuts and Jobs Act of 2017 and modifying a...more
The U.S. Congress has enacted the One Big Beautiful Bill Act (OBBB), formally renamed "An Act to provide for reconciliation pursuant to title II of H. Con. Res. 14." President Donald Trump signed the legislation into law on...more
The Legislation combines spending and policy priorities from 11 congressional committees and will reshape federal policy across nearly every sector of the U.S. economy. There is a possibility for one or more additional...more
This bulletin follows our previous update on evolving U.S. tax reform, which highlighted the competing House and Senate proposals, particularly the introduction and scope of proposed Section 899 targeting "unfair foreign...more
On July 4, President Trump signed into law H.R. 1, (the “One Big Beautiful Bill Act” (“OBBBA”)), a sweeping legislation package featuring significant changes to U.S. tax law. The OBBBA was passed via a budget reconciliation...more
With a name like the One Big Beautiful Bill Act (OBBBA), you know two things right away: (1) it’s a mouthful, and (2) you’re going to have to wade through a lot to find the useful parts. Fortunately, two tax lawyers already...more
On July 4, 2025, US President Donald Trump signed the One Big Beautiful Bill Act (OBBBA) into law. The legislation introduces significant changes to both international and domestic business tax rules for US taxpayers. While...more
On July 4, 2025, President Trump signed into law the One Big Beautiful Bill Act (OBBBA), marking a significant overhaul of the international tax landscape. This legislation introduces several key changes aimed at refining...more
On July 4th, 2025, President Trump signed into law the One Big Beautiful Bill Act (“OBBBA”). This alert expands upon our Firm’s prior alert and is intended to summarize the main tax law changes that may impact: (i) U.S....more
On July 4, 2025, President Trump signed into law the “One Big Beautiful Bill Act” (the “2025 Act”). The Act makes permanent some provisions originally enacted in 2017 as part of the Tax Cuts and Jobs Act (the “2017 Act”),...more