26 episodes

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.

GILTI Conscience Skadden, Arps, Slate, Meagher & Flom LLP

    • Business
    • 4.7 • 22 Ratings

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.

    Inside the IRS: A Conversation With Former Agency Officials

    Inside the IRS: A Conversation With Former Agency Officials

    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 funding, enforcement priorities and tips for a more successful interaction with the IRS.
    Want more? Check out this prior episode with Fred Goldberg as he shares insights from his 50 years in tax law.
    💡 Featured Guest 💡Name: Fred Goldberg
    What he does: Fred is of counsel in Skadden’s Tax Group. He represents business, tax-exempt and individual clients in all phases of dispute resolution with tax authorities. A primary focus of his practice has been to resolve large and complex tax controversies related to a wide range of issues across all industries. Fred is a former IRS chief counsel, IRS commissioner and Department of the Treasury assistant secretary for tax policy. 
    Organization: Skadden  
    Words of wisdom: “This is the first time ever the IRS has had serious long-term funding. … But it didn't take Congress long to start taking it back.” 
    Connect: LinkedIn 
    Name: De Lon Harris  
    What he does:  De Lon is a senior advisor for tax resolution strategies in Skadden’s Tax Group, where he counsels clients on a wide range of tax controversy matters. De Lon has over three decades of experience at the IRS, including serving in numerous executive positions. Earlier in his career, De Lon also participated in a one-year fellowship with the U.S. House of Representatives Ways and Means Oversight Subcommittee.
    Organization: Skadden   
    Words of wisdom: “I want to talk about what these folks that fall within that large partnership and large corporate categories should be thinking about, especially if they haven't been audited before. And the one thing they should be thinking about is they are eligible, under Revenue Procedure 2022-39, they're an eligible taxpayer that they can disclose issues that need to be adjusted without penalties, instead of having to file a qualified amended return.” 
    Connect: LinkedIn 
    Connect with Skadden☑️ Follow us on Twitter & LinkedIn.
    ☑️ Subscribe to GILTI Conscience on Apple Podcasts, a href="https://open.spotify.com/show/3nNf0ip6ooZ6ilbhpBJ4lR" rel="noopener noreferrer"...

    • 35 min
    Pillar Two Analysis: An Asia-Pacific Viewpoint

    Pillar Two Analysis: An Asia-Pacific Viewpoint

    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 viewpoint of Pillar Two in Japan, as well as in the larger Asia Pacific region. The conversation also includes how Pillar Two is coming into play in other areas across the continent, including transfer pricing, training and knowledge base, and enforcement, as well as the effects on multinationals doing business throughout the region.
    💡 Featured Guest 💡Name: Samuel Gordon
    What he does: Samuel is a bilingual transfer pricing partner at Deloitte, advising firms in Japan and the Asia Pacific region. He has experience in planning, documentation, risk assessments, advance pricing arrangements, transfer pricing governance, and M&A and restructuring.
    Organization: Deloitte
    Words of wisdom: “I'm an American who's lived in Japan a long time. My observation is the U.S. is always close to the OECD, but very concerned about maintaining … that sovereign perspective. We don't have that as much in Japan. … [T]here may be some interpretive differences, but I don't think that you're going to see any differences with respect to the rulemaking per se.”
    Connect: LinkedIn 
    Connect with Skadden☑️ Follow us on Twitter & LinkedIn.
    ☑️ Subscribe to GILTI Conscience on Apple Podcasts, Spotify, Google Podcasts, or your favorite podcast app.
    ☑️ Let us know what topics you would like to hear about on GILTI Conscience by emailing our executive producer at eman.cuyler@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. The insights and views presented in GILTI Conscience are for general information purposes only and should not be taken as legal advice for any individual case or situation. The information presented is not a substitute for consulting with an attorney, nor does tuning into this podcast constitute an attorney-client relationship of any kind.

    • 40 min
    Insuring Transfer Pricing Risk

    Insuring Transfer Pricing Risk

    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 Conscience” podcast, hosts Nate Carden and David Farhat are joined by Skadden’s Eman Cuyler and Stefane Victor and Yoav Shans of McGill and Partners to discuss the ins and outs of tax insurance including how it relates to transfer pricing, how a claim is initiated and insuring a position.
    💡 Featured Guest 💡Name: Yoav Shans
    What he does: Yoav is a partner and tax lead in McGill and Partner’s M&A team, leading the global specialty tax insurance practice. Yoav’s industry experience includes diversified industrial products, consumer products, IT solutions and energy.
    Organization: McGill and Partners
    Words of wisdom: “Tax insurance essentially is a risk mitigation tool.” 
    Connect: LinkedIn
    Connect with Skadden☑️ Follow us on Twitter & LinkedIn.
    ☑️ Subscribe to GILTI Conscience on Apple Podcasts, Spotify, Google Podcasts, or your favorite podcast app.
    ☑️ Let us know what topics you would like to hear about on GILTI Conscience by emailing our executive producer at eman.cuyler@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. The insights and views presented in GILTI Conscience are for general information purposes only and should not be taken as legal advice for any individual case or situation. The information presented is not a substitute for consulting with an attorney, nor does tuning into this podcast constitute an attorney-client relationship of any kind.

    • 34 min
    Gearing Up for Pillar Two

    Gearing Up for Pillar Two

    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 as changes and adjustments are likely during the implementation process. 
    💡 Featured Guests 💡Name: Eric Sensenbrenner
    What he does: Eric is the head of Skadden’s Global Tax Group and represents clients on a broad range of U.S. and international tax matters, with a particular emphasis on transactional tax planning in the international context.
    Organization: Skadden
    Words of wisdom: “You've got to think more about systemic and operational changes.” 
    Connect: LinkedIn 
    Name: Paul Oosterhuis
    What he does: Paul is an internationally recognized senior practitioner in the area of international tax. He has extensive experience in mergers and acquisitions, post-acquisition integration, spin-offs, internal restructuring and joint ventures. He also represents multinational companies in non-transactional international tax planning and assists clients in resolving high-stakes, complex tax controversies.
    Organization: Skadden
    Words of wisdom: “ I think we all need to just kind of keep our seat belts tight until we see the outcome of the 2024 election to see if we're going to be part of the Pillar two community or if we're gonna be bucking the Pillar two community.”
    Connect: LinkedIn 
    Connect with Skadden☑️ Follow us on Twitter & LinkedIn.
    ☑️ Subscribe to GILTI Conscience on Apple Podcasts, Spotify, Google Podcasts, or your favorite podcast app.
    ☑️ Let us know what topics you would like to hear about on GILTI Conscience by emailing our executive producer at eman.cuyler@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. The insights and views presented in...

    • 38 min
    Spotlight Series: Utilizing Tax Knowledge for the Greater Good

    Spotlight Series: Utilizing Tax Knowledge for the Greater Good

    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 tax and their experiences and motivations behind taking on this type of work.
    Both Sanessa and Jared provide examples of how to find pro bono projects that are a good fit for their practices. For Sanessa, finding causes that are aligned with her values and interests motivate her to say yes. Jared explains, "If I have time to work on it, I usually just say yes. I'm not picky because you never really know what issues are going to come up. It's always a learning experience."
    💡 Featured Guests 💡Name: Sanessa Griffiths
    What she does: Sanessa advises clients on a broad range of tax controversy matters and transactional situations. Her practice focuses on matters related to high-stakes and complex tax controversies involving transfer pricing, economic substance and business purpose doctrines, and tax treaty interpretation. 
    Organization: Skadden
    Words of wisdom: “There are so many things you can do in pro bono, even within just the realm of tax pro bono, that'll make you a better lawyer while contributing to society.” 
    Connect: LinkedIn 
    Name: Jared Binstock
    What he does: Jared advises on the tax aspects of debt and equity financings, initial public offerings, bankruptcy restructurings, and internal integration and restructuring transactions. In addition to his broad-based M&A tax practice, he counsels clients in the financial services sector on insurance-related corporate transactions, including capital raising, reinsurance transactions and restructurings.
    Organization: Skadden
    Words of wisdom: “One of my favorite parts about practicing tax has been the experience that I've had in pro bono.” 
    Connect: LinkedIn
    Connect with Skadden☑️ Follow us on Twitter & LinkedIn.
    ☑️ Subscribe to GILTI Conscience on Apple Podcasts, Spotify, Google Podcasts, or your favorite podcast app.
    ☑️ Let us know what topics you would like to hear about on GILTI Conscience by emailing our executive producer at a...

    • 29 min
    Tax Insurance 101

    Tax Insurance 101

    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 various jurisdictions come into play.
    The conversation takes listeners through the impact that evolving international tax law has had on tax insurance; what multinationals need to consider when exploring a policy; recognizing risk, particularly surrounding BEPS; and tax insurance in an M&A transaction.
    💡 Featured Guest 💡Name: Michael Gaffney
    What he does: Mike is a director and a member of Atlantic Global Risk’s tax team responsible for tax liability insurance products. Prior to joining Atlantic, Mike most recently was PwC’s global tax leader for the banking and capital markets practice and advised financial institutions on complex tax matters. He has authored several articles on international tax, financial products and transfer pricing.
    Organization: Atlantic Global Risk
    Words of wisdom: “The way I think of the product is it’s a tool for advisors to have and for taxpayers to know about.” 
    Connect: LinkedIn
    Connect with Skadden☑️ Follow us on Twitter & LinkedIn.
    ☑️ Subscribe to GILTI Conscience on Apple Podcasts, Spotify, Google Podcasts, or your favorite podcast app.
    ☑️ Let us know what topics you would like to hear about on GILTI Conscience by emailing our executive producer at eman.cuyler@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. The insights and views presented in GILTI Conscience are for general information purposes only and should not be taken as legal advice for any individual case or situation. The information presented is not a substitute for consulting with an attorney, nor does tuning into this podcast constitute an attorney-client relationship of any kind.

    • 30 min

Customer Reviews

4.7 out of 5
22 Ratings

22 Ratings

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