GILTI Conscience

Conversations surrounding transfer pricing practices rarely span to include the myriad regulations throughout Africa. However, across the continent, there are vast distinctions between countries that are thriving under new international tax rules and others that are struggling to keep up.  Lolade Ososami, a partner and head of the tax team at Udo Udoma & Belo-Osagie, says that transfer pr...

In an effort to address tax issues surrounding the ever-growing digitalization of the global economy, the OECD proposed blueprint plans called Pillar One and Pillar Two. Though they were introduced  in October 2020, implementation remains a challenge.  In this episode of the GILTI Conscience podcast, Europe tax head James Anderson and London tax partner Alex Jupp join our hosts to discus...

For many low-income individuals,  filing taxes may be a daunting task, and many may even choose to avoid interacting with the IRS altogether due to negative experiences. However, not filing taxes may mean missing out on crucial refunds and benefits..  From low-income taxpayer clinics in communities to organizations and initiatives such as VITA , GetYourRefund and Code For America , there...

The OECD transfer pricing guidelines include DEMPE — the development, enhancement, maintenance, protection and exploitation of intangibles — as part of their efforts to deal with the legal status of both IP and economic ownership. Originally, the regulations stated that only legal ownership existed; DEMPE was incorporated to accommodate contributions made by entities other than the legal owner.&nb...

In this episode of the “GILTI Conscience” podcast, Roger Brown, global head of Tax Strategy at Chainalysis, joins our hosts Nate Carden and David Farhat to talk about the basics of blockchain. Roger explains what blockchain is, how tax rules apply to crypto and the field’s potential benefits. Roger says that people regularly approach him with questions about blockchain and crypto — although the se...

In this episode of the “GILTI Conscience” podcast, longtime Skadden tax partner Fred Goldberg joins our hosts Nate Carden and David Farhat to discuss his one-of-a-kind journey through the public and private tax sectors. Fred details the changes he’s seen, his hopes for the future of the field and his advice for those looking to begin a career in tax law. As Fred notes, the tax system is the one se...

In this episode of the “GILTI Conscience” podcast, Bram Isgur, principal at Keystone Strategy, joins our hosts Nate Carden and David Farhat to talk about transfer pricing on an ex ante and ex post basis. They discuss the use cases for each method, how these methods differ across industries and why it’s important to think about the bigger picture in preparing for unimaginable events and changes.&nb...

In this episode of the “GILTI Conscience” podcast, Kroll directors Ryan Lange and Kerim Keser and Skadden partner Johannes Frey join our hosts Nate Carden and David Farhat to explore the details of the German nonresident IP withholding tax. They discuss taxation questions that are still up in the air, how the rule could affect multinational corporations, the valuation of intellectual property (IP)...

In this episode of the “GILTI Conscience” podcast, Skadden international tax attorney Paul Oosterhuis and associate Huzefa Mun join our hosts Nate Carden and David Farhat to discuss legislation, new regulations and the Build Back Better Act. They examine possible outcomes if the Build Back Better Act is not adopted, including changes in other tax regulations that could arise, as well as the potent...

In this episode of the GILTI Conscience podcast, Loren Ponds, Member at Miller & Chevalier in Washington, D.C., joins our hosts to share an overview of the tax legislative process. She discusses the outlook for current tax bills moving through the house and how changes and feedback are incorporated. Over the past two decades, most of the major tax legislation has gone through a reconciliation...

Diversity, equity and inclusion (DEI) make business sense for every professional community. For the tax practice, where creativity is essential, diversity elevates the practice, benefitting everyone from clients to the government and practitioners themselves. The tax community, however, lacks DEI for a host of reasons. At the heart of the problem is the ubiquity of whiteness and a pervasive insens...

Understanding the 2022 OECD Transfer Pricing Guidelines and how it applies to guarantees and other financial transactions is essential for multinationals trying to manage intercompany lending and get their transfer pricing right. Granted, these companies have to fund themselves, whether through intercompany debt or guaranteed loans. They have to move money across borders, but how they do that, how...

The team at Skadden, Arps, Slate, Meagher & Flom LLP is always happy to debate multinational tax issues. And with the way things have been changing in the last two years, it’s never been a better time to hit "record" on those conversations, and share them with fellow self-proclaimed tax nerds and those just getting started in the field. “Five years ago, we had a radically different internation...

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 add...