Taxing Intelligence: AI's Role in Modern Tax Administration
GILTI Conscience Podcast | Navigating Permanent Establishments in International Tax Law
GILTI Conscience Podcast | Spotlight Series: A Celebration of Pride Month With IRS Veteran De Lon Harris
GILTI Conscience Podcast | Dissecting Cross-Border Transfer Pricing Resolutions
GILTI Conscience Podcast | Spotlight Series: A Conversation With Women Trailblazers in Tax
GILTI Conscience Podcast | Inside the IRS: A Conversation With Former Agency Officials
GILTI Conscience Podcast | Pillar Two Analysis: An Asia Pacific Viewpoint
GILTI Conscience Podcast | Gearing Up for Pillar Two
GILTI Conscience Podcast | Spotlight Series: Utilizing Tax Knowledge for the Greater Good
GILTI Conscience Podcast | Spotlight Series: An Evolution of Workplace Diversity and Acceptance
GILTI Conscience Podcast | Amount B Back in the Spotlight
GILTI Conscience Podcast | Update on Pillar Two: Where it Stands Today and What To Expect
GILTI Conscience Podcast | Spotlight Series: Beyond the Technical Side of Tax Law
GILTI Conscience Podcast | Spotlight Series: Pro Bono Opportunities in the Tax World
Musings on Multinational Tax: What to Expect From GILTI Conscience
On July 4, 2025, President Trump signed into law the “One Big Beautiful Bill Act” (the “2025 Act”). The Act makes permanent some provisions originally enacted in 2017 as part of the Tax Cuts and Jobs Act (the “2017 Act”),...more
On July 4, 2025, the “One Big Beautiful Bill Act” (OBBBA) became law. The OBBBA makes significant changes to domestic and international tax provisions, including provisions addressing bonus depreciation, research and...more
On July 4, 2025, President Donald J. Trump signed the One Big Beautiful Bill Act (the “OBBBA”) into law. Congress passed the OBBBA through budget reconciliation, a special legislative process that allows Congress to advance...more
The House of Representatives previously passed H.R. 1-119th Congress (2025-2026), titled the “One, Big, Beautiful Bill Act” (the “Act”), a budget bill that, among other things, addresses sunsetting provisions of the Tax Cuts...more
Key Points - - The Senate Finance Committee’s version of the tax-related proposals aim to deliver on Senate Republicans’ promise to make many of the TCJA’s individual and corporate tax measures permanent. - The bill...more
As the U.S. tax reform process continues, the comprehensive tax bill that passed the House of Representatives in May is now under active consideration in the Senate. Earlier this week, the Senate Finance Committee released...more
On May 22, 2025, the House of Representatives passed the One Big Beautiful Bill Act (OBBBA). Tax-related proposals contained in the OBBBA would extend or make permanent select corporate, international and individual tax...more
On Thursday May 22, the House of Representatives passed the One Big Beautiful Bill Act (H.R. 1, hereafter the “Bill”). The Bill will now be considered by the U.S. Senate....more
On May 12, the Republican majority leadership in the House of Representatives released for consideration its tax and spending reconciliation legislation, called the “One Big, Beautiful Bill” (the “Bill”). This major piece of...more
The race to remake portions of the Internal Revenue Code (Code) and to prevent expiration of certain Tax Cuts and Jobs Act (TCJA) provisions has begun, with House Ways & Means Committee proposals (the Markup) to spend...more
On Friday, May 9, the House Ways and Means Committee released a portion of its draft tax legislation (the “House Draft Bill”) to amend the Internal Revenue Code of 1986 (the “Code”). The House Draft Bill is primarily...more
Since the proposed dual consolidated loss (DCL) and disregarded payment loss (DPL) rules were released in August 2024, taxpayers have been wondering whether these controversial regulations would be finalized before the end of...more
With clear Republican victories in the White House and the Senate, and a very slim majority for either side in the House of Representatives, we can expect tax legislation in the coming year. It is expected that the President...more
The U.S. Supreme Court on June 20, 2024, ruled 7-2 that Section 965 of the Internal Revenue Code, as revised by the law known as the Tax Cuts and Jobs Act, is constitutional. The issue presented to the Court in Moore v....more
In celebration of Pride Month, tax senior advisor De Lon Harris joins Eman Cuyler and Stefane Victor on “GILTI Conscience,” where he discusses his life and career as a gay professional. De Lon talks about his 30-plus years at...more
Durante años, había existido incertidumbre entre los profesionistas que se dedican a la materia fiscal sobre sobre si las ganancias obtenidas a mitad de año por una Corporación Extranjera Controlada (por sus siglas en inglés,...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
The IRS won a major economic substance case on October 31. A federal district court in Liberty Global, Inc. v. United States, No. 20-cv-03501 (D. Colo.), found that a planned corporate transaction lacked economic substance. ...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
On July 3, 2023, New Jersey Governor Phil Murphy signed into law S.B. 3737 / A.B. 5323 (the “Bill”), which makes significant changes to the Corporation Business Tax (“CBT”). Some of the most noteworthy changes are summarized...more
On March 9, 2023, the Treasury Department released the General Explanations of the Administration’s Fiscal Year 2024 Revenue Proposals (sometimes called the Green Book) to accompany President Joe Biden’s proposed budget for...more
On December 9, 2022, Treasury released proposed regulations that would prevent consolidated groups from engaging in certain related party transactions to reduce the group’s Subpart F and GILTI inclusions. Specifically,...more
Section 245A: Tax Efficient Repatriation of a Foreign Subsidiary’s Earnings - Freeman Law frequently advises U.S. multinational corporations. United States-based international businesses are subject to complex reporting...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