Join us for an insightful episode of “GILTI Conscience” as David Farhat, Eman Cuyler and Stefane Victor — together with our special host Skadden tax partner Loren Ponds and guest Fernando Colucci, partner at Machado Meyer in...more
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
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
With more and more countries signing on to Pillar Two, “GILTI Conscience” hosts Nate Carden and David Farhat are joined by Vikram Chand, associate professor of law at the University of Lausanne, to discuss what this means for...more
5/24/2023
/ Business Taxes ,
Corporate Taxes ,
Foreign Corporations ,
GILTI tax ,
International Tax Issues ,
New Legislation ,
New Regulations ,
OECD ,
Tax Legislation ,
Tax Planning ,
Tax Policy
For law students or young practitioners pursuing a career in tax law, there are numerous possibilities to gain hands on experience and knowledge. However, learning about and finding an entry into transfer pricing may be much...more
4/19/2023
/ Business Taxes ,
Corporate Taxes ,
International Tax Issues ,
International Trade ,
Mentor-Protege Program ,
Mentors ,
OECD ,
Tax Legislation ,
Tax Planning ,
Transfer Pricing ,
Young Lawyers
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 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
Takeaways -
Transfer pricing uncertainly has increased with U.S. tax reforms and an OECD proposal establishing a new approach to determining the jurisdiction where income is recognized.
The “competent authority...more