On September 10, 2024, the European Court of Justice (ECJ or Court) sided with the European Commission (Commission) and ruled that two Irish subsidiaries of Apple Inc. received unlawful state aid from Ireland in the form of a...more
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
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
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
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
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
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
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
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
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
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
Adoption of the OECD Pillar Two model rules implementing accords on a global minimum corporate tax rate may result in anomalous or unfair results for some multinationals. Protections available under investment treaties,...more
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
On November 16, 2022, the IRS released a long-awaited update to the procedure for large corporate taxpayers and large partnerships under continuous audit to obtain Qualified Amended Return (QAR) treatment for items disclosed...more
On November 8, 2022, the Court of Justice of the European Union (CJEU), overturning the first instance EU General Court (General Court), annulled the European Commission’s (EC’s) decision that a Luxembourg tax ruling on...more
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
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
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
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
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
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
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
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
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
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