Multinational groups adopting cost contribution arrangements (CCAs) — or cost share agreements in US parlance — as part of their cross-border intellectual property (IP) development strategies have a new opportunity to...more
7/9/2025
/ Corporate Taxes ,
Cross-Border ,
HM Treasury ,
HMRC ,
Intellectual Property Protection ,
International Tax Issues ,
Multinationals ,
OECD ,
Tax Planning ,
Taxation ,
Transfer Pricing ,
UK
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
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 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
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
The question is no longer whether the volatility created by the COVID-19 pandemic will deepen the difficulties businesses and other institutions face in the coming months, but by how much and in what ways. In the past few...more
3/21/2020
/ Acquisitions ,
Antitrust Provisions ,
Audits ,
Board of Directors ,
Coronavirus/COVID-19 ,
Corporate Restructuring ,
Corporate Taxes ,
Court Closures ,
Debt-Equity ,
Energy Projects ,
Families First Coronavirus Response Act (FFCRA) ,
IRS ,
Liquidity ,
Mergers ,
Power Infrastructure ,
Securities Litigation ,
Shareholder Activism ,
Shareholder Meetings ,
Stock Repurchases
On September 24, 2019, the EU General Court (General Court) issued its long-awaited judgments in relation to the appeals brought against two European Commission (EC) decisions of 2015 concluding that tax rulings granted by...more
9/30/2019
/ Arm's Length Principle ,
Benchmarks ,
Business Profits ,
Corporate Counsel ,
Corporate Taxes ,
European Commission ,
Fiat ,
General Court of the European Union (GCEU) ,
Luxembourg ,
Member State ,
Netherlands ,
Regulatory Authority ,
Starbucks ,
State Aid ,
Tax Litigation ,
Treaty on the Functioning of the European Union (TFEU)
On March 8, 2017, Skadden hosted a webinar titled “Lessons Learned From Tax-Related Whistleblower Litigation and Shareholder Actions.” The Skadden panelists were tax partners Nathaniel Carden and Armando Gomez, and litigation...more
3/22/2017
/ 1099s ,
Board of Directors ,
Breach of Duty ,
Class Action ,
Corporate Taxes ,
Derivative Suit ,
Dodd-Frank ,
False Claims Act (FCA) ,
Federal v State Law Application ,
Form 1098-T ,
Internal Revenue Code (IRC) ,
International Tax Issues ,
Inversion ,
IRS ,
Misrepresentation ,
Securities and Exchange Commission (SEC) ,
Securities Fraud ,
Securities Litigation ,
Shareholder Litigation ,
Stock Drop Litigation ,
Tax Litigation ,
Tax Planning ,
Whistleblowers
On February 16, 2017, Skadden hosted a webinar titled “Prospects for U.S. Business Tax Reform: What You Need to Know.” The Skadden panelists were M&A partner Stephen Arcano; global tax co-head Eric Sensenbrenner; and tax...more
2/28/2017
/ Business Taxes ,
Capital Markets ,
Corporate Taxes ,
DBCF Tax ,
Exports ,
Foreign Earned Income ,
Imports ,
International Tax Issues ,
Legislative Agendas ,
Multinationals ,
Offshore Funds ,
Repatriation ,
Tax Reform ,
Trump Administration ,
Value-Added Tax (VAT) ,
WTO
On Wednesday, the U.K. Government released draft legislation to be effective on 1 April 2015, which will impose a “diverted profits tax” (DPT) at 25 percent of the amount of profits deemed to have been diverted from the U.K....more
Introduction -
Following on its February 2013 report on Addressing Base Erosion and Profit Shifting (BEPS), the Organisation for Economic Co-operation and Development (OECD) has now released an ambitious action plan...more