GILTI Conscience Podcast | Beyond the Runway: Navigating Tax, Tariffs and Transfer Pricing in Luxury Fashion
On July 4, 2025, President Donald Trump signed into law the One Big Beautiful Bill Act (H.R.1) (OBBBA). This alert focuses on OBBBA changes regarding qualified small business stock (QSBS) and qualified opportunity zone (QOZ)...more
“GILTI Conscience” takes on the world of high-fashion, as Skadden tax partner and host David Farhat is joined by associate Stefane Victor and Giuseppe Abatista, vice president at Banca Popolare di Puglia e Basilicata, as they...more
On 3 April 2025, in the case of Nordcurrent Group UAB (C-228/24) (“Nordcurrent”) the Court of Justice of the European Union (the “CJEU”) provided a preliminary ruling on the interpretation of the anti-abuse provisions in...more
Charitable organizations are dependent, in no small part, upon the financial support of many successful business owners. The generosity of these individuals and their organizations may be a manifestation of several factors...more
In the Soundtrack of Our Lives, one of the songs that I still get to hear from time to time on Sirius XM, is “Still the One” which was recorded and released by the band Orleans in 1976. I was in the tenth grade just to be...more
Cada año, el Servicio de Impuestos Internos (SII) actualiza la guía denominada Catálogo de Esquemas Tributarios, que contiene un listado de operaciones que pueden ser declaradas elusivas por aplicación de la Norma General...more
Companies must approach HMRC with suitable care when proposing a restructuring plan, mindful of lessons learned from recent case law. Ever since unpaid taxes due to HMRC were “crammed down” pursuant to a restructuring plan...more
Welcome to the September edition of the UK Tax Round Up. This month has seen interesting decisions on the salaried members rules, the scope of arrangements for the CGT rollover main tax avoidance purpose test and the...more
On September 22, 2023 a federal jury convicted two promoters, CPA Jack Fisher and attorney James Sinnott, in the Department of Justice’s (“DOJ”) first criminal trial over allegedly abusive syndicated conservation easements...more
On November 9, 2022, in a 15-2 decision, the Tax Court held that the IRS improperly issued Notice 2017-10 in Green Valley Investors, LLC, et al. v. Commissioner of Internal Revenue, 159 T.C. No. 5. The Notice designated...more
Bank of England market intervention after presentation of tax package - On 23 September, the new U.K. Government conducted the emergency fiscal event it had scheduled when taking power at the beginning of the month. Many...more
In Chico v. Commissioner, the taxpayers challenged the Tax Court’s assessment of a fraud penalty. The Tax Court had imposed civil fraud penalties against the married taxpayers, finding clear-and-convincing evidence of fraud...more
The Duke of Westminster Principle Still Lives On for Tax Planning - On November 26, 2021, the Supreme Court of Canada released its decision and reasons in Her Majesty the Queen and Alta Energy Luxembourg S.A.R.L., 2021 SCC...more
Promoting abusive tax shelters. Taxpayers and tax return preparers should be aware of the various penalties that exist and can be assessed for certain actions (or nonactions). One such action includes promoting an abusive tax...more
A “qualified amended return” is an amended tax return that, if properly filed before a taxpayer is “on the IRS’s radar,” protects a taxpayer against accuracy-related penalties—in layman’s terms, it is a get-out-of-jail-free...more
The IRS recently concluded its 2021 four-part series of the “Dirty Dozen” tax-related scams. The fourth installment focuses on what the Service refers to as “schemes peddled by tax promoters, including syndicated...more
On May 18, 2021, the European Commission (the Commission) of the European Union (the EU) published a communication on “Business Taxation for the 21st Century” (the Communication), setting out a long-term vision to provide a...more
Spring Budget and Tax Day - After months of speculation about the possibility that capital gains tax (CGT) rates would be increased in the Spring Budget, both it and the government’s follow up “Tax Day” on 23 March passed...more
According to Justice Learned Hand, “Any one may so arrange his affairs that his taxes shall be as low as possible; he is not bound to choose that pattern which will best pay the Treasury; there is not even a patriotic duty to...more
UK Case Law Developments - EIS relief not available for shares carrying preferential rights - The Upper Tribunal (UT) in Foojit v HMRC dismissed the taxpayer’s appeal against the First-tier Tribunal’s (FTT’s) decision...more
UK COVID-19 Developments - Extension of support for retail, leisure and hospitality businesses - Further to the extension of the Coronavirus Job Retention Scheme (or furlough scheme), reported in the November issue of...more
UK COVID-19 Developments - Extension of support for employed and self-employed workers - On 5 November, the UK Chancellor announced the extension of the Coronavirus Job Retention Scheme (or furlough scheme) to the end...more
A recent disclosure by the Indiana Department of Revenue shows that a trend toward states engaging in transfer pricing in earnest is gaining traction. This shift requires a change in approach to defending intercompany...more
I say Settlor… The popularity of lifetime trust giving in the UK has been on a downward trend since April 2006 when the Labour government introduced reforms specifically aimed at stopping trusts “being used to shelter wealth...more
The Chancellor of the Exchequer delivered the United Kingdom (“UK”) Budget for 2020 on 11 March 2020. The Budget was delivered against a backdrop that very few people could have anticipated at the commencement of the year....more