GILTI Conscience Skadden, Arps, Slate, Meagher & Flom LLP

In this episode of the “GILTI Conscience” podcast, Skadden attorneys Eman Cuyler and Stefane Victor are joined by Jessica Hough, tax partner and head of Skadden’s Washington, D.C. office, and Pam Olson, a tax policy consultant at PwC, both of whom have significant experience advising on issues related to tax policy.
Tune in to this special episode in which two very distinguished women leaders within the tax community share their insights, experience and strategies for success, as well as how to lead with purpose.
💡 Featured Guests 💡Name: Pam Olson
What she does: Pam is a tax policy consultant at PwC. She previously served as the U.S. deputy tax leader and Washington National Tax Services (WNTS) practice leader of PwC. Before joining PwC, Pam served as assistant secretary for Tax Policy at the U.S. Department of the Treasury and head of Skadden’s Washington, D.C. Tax Group.
Organization: PwC
Words of wisdom: “We learn so much from people with different backgrounds than our own and different experiences than our own. And so, it's really important to surround yourself with people who aren't all cut from the same cloth.’ 
Connect: LinkedIn 
Name: Jessica Hough
What she does: Jessica is a partner in Skadden’s tax practice and head of the firm’s Washington, D.C. office, where she represents clients on a wide range of tax matters, with particular emphasis on mergers, acquisitions and divestiture transactions, including spin-offs, debt and equity offerings, corporate and partnership restructurings, and joint ventures.   
Organization: Skadden   
Words of wisdom: “The key to developing a mentor-mentee relationship is to be yourself because the whole point of cultivating or forming that relationship is that you're finding some kind of commonality.”
Connect: LinkedIn 
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On this episode of the “GILTI Conscience” podcast, Skadden attorneys David Farhat, Nate Carden, Eman Cuyler and Stefane Victor, are joined by colleagues Fred Goldberg and De Lon Harris, both of whom have had distinguished careers with the IRS.  
Tune in to hear Fred and De Lon share their thoughts, insights and predictions on the latest IRS projects and initiatives, as they talk about what's going on at the agency, new funding, enforcement priorities and tips for a more successful interaction with the IRS.
Want more? Check out this prior episode with Fred Goldberg as he shares insights from his 50 years in tax law.
💡 Featured Guest 💡Name: Fred Goldberg
What he does: Fred is of counsel in Skadden’s Tax Group. He represents business, tax-exempt and individual clients in all phases of dispute resolution with tax authorities. A primary focus of his practice has been to resolve large and complex tax controversies related to a wide range of issues across all industries. Fred is a former IRS chief counsel, IRS commissioner and Department of the Treasury assistant secretary for tax policy. 
Organization: Skadden  
Words of wisdom: “This is the first time ever the IRS has had serious long-term funding. … But it didn't take Congress long to start taking it back.” 
Connect: LinkedIn 
Name: De Lon Harris  
What he does:  De Lon is a senior advisor for tax resolution strategies in Skadden’s Tax Group, where he counsels clients on a wide range of tax controversy matters. De Lon has over three decades of experience at the IRS, including serving in numerous executive positions. Earlier in his career, De Lon also participated in a one-year fellowship with the U.S. House of Representatives Ways and Means Oversight Subcommittee.
Organization: Skadden   
Words of wisdom: “I want to talk about what these folks that fall within that large partnership and large corporate categories should be thinking about, especially if they haven't been audited before. And the one thing they should be thinking about is they are eligible, under Revenue Procedure 2022-39, they're an eligible taxpayer that they can disclose issues that need to be adjusted without penalties, instead of having to file a qualified amended return.” 
Connect: LinkedIn 
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The evolving landscape of tax reforms in Japan and the broader Asia Pacific region presents a complex tapestry of challenges and strategic shifts.
On this episode of the “GILTI Conscience” podcast, Skadden partners Nate Carden and David Farhat are joined by Samuel Gordon, an international tax partner at Deloitte in Japan to dissect tax implications, reform and concerns in this part of the globe.
The discussion delves into the viewpoint of Pillar Two in Japan, as well as in the larger Asia Pacific region. The conversation also includes how Pillar Two is coming into play in other areas across the continent, including transfer pricing, training and knowledge base, and enforcement, as well as the effects on multinationals doing business throughout the region.
💡 Featured Guest 💡Name: Samuel Gordon
What he does: Samuel is a bilingual transfer pricing partner at Deloitte, advising firms in Japan and the Asia Pacific region. He has experience in planning, documentation, risk assessments, advance pricing arrangements, transfer pricing governance, and M&A and restructuring.
Organization: Deloitte
Words of wisdom: “I'm an American who's lived in Japan a long time. My observation is the U.S. is always close to the OECD, but very concerned about maintaining … that sovereign perspective. We don't have that as much in Japan. … [T]here may be some interpretive differences, but I don't think that you're going to see any differences with respect to the rulemaking per se.”
Connect: LinkedIn 
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☑️ Subscribe to GILTI Conscience on Apple Podcasts, Spotify, Google Podcasts, or your favorite podcast app.
☑️ Let us know what topics you would like to hear about on GILTI Conscience by emailing our executive producer at eman.cuyler@skadden.com.
GILTI Conscience is a podcast by Skadden, Arps, Slate, Meagher & Flom LLP, and Affiliates. Skadden’s tax team is recognized globally for providing clients with creative and innovative solutions to their most pressing transactional, planning, and controversy challenges. The insights and views presented in GILTI Conscience are for general information purposes only and should not be taken as legal advice for any individual case or situation. The information presented is not a substitute for consulting with an attorney, nor does tuning into this podcast constitute an attorney-client relationship of any kind.

While tax insurance can be used in a variety of contexts, from M&A deals to regular tax planning scenarios, it is also relevant when it comes to transfer pricing. Recent developments have expanded the scope of tax insurance to cover multiple years of transfer pricing in returns in M&A deals, and the potential of seeing more transfer pricing insurance in the future is a strong possibility.
On this episode of the “GILTI Conscience” podcast, hosts Nate Carden and David Farhat are joined by Skadden’s Eman Cuyler and Stefane Victor and Yoav Shans of McGill and Partners to discuss the ins and outs of tax insurance including how it relates to transfer pricing, how a claim is initiated and insuring a position.
💡 Featured Guest 💡Name: Yoav Shans
What he does: Yoav is a partner and tax lead in McGill and Partner’s M&A team, leading the global specialty tax insurance practice. Yoav’s industry experience includes diversified industrial products, consumer products, IT solutions and energy.
Organization: McGill and Partners
Words of wisdom: “Tax insurance essentially is a risk mitigation tool.” 
Connect: LinkedIn
Connect with Skadden☑️ Follow us on Twitter & LinkedIn.
☑️ Subscribe to GILTI Conscience on Apple Podcasts, Spotify, Google Podcasts, or your favorite podcast app.
☑️ Let us know what topics you would like to hear about on GILTI Conscience by emailing our executive producer at eman.cuyler@skadden.com.
GILTI Conscience is a podcast by Skadden, Arps, Slate, Meagher & Flom LLP, and Affiliates. Skadden’s tax team is recognized globally for providing clients with creative and innovative solutions to their most pressing transactional, planning, and controversy challenges. The insights and views presented in GILTI Conscience are for general information purposes only and should not be taken as legal advice for any individual case or situation. The information presented is not a substitute for consulting with an attorney, nor does tuning into this podcast constitute an attorney-client relationship of any kind.

Pillar Two is no longer hypothetical. It’s now time for Pillar Two “readiness.”
In this episode of the “GILTI Conscience” podcast, hosts David Farhat, Nate Carden, Eman Cuyler and Stefane Victor discuss Pillar Two with Eric Sensenbrenner and Paul Oosterhuis. The group delves into the current state of Pillar Two, which has shifted from a source of concern to a challenge being actively addressed. Companies will have to remain nimble as changes and adjustments are likely during the implementation process. 
💡 Featured Guests 💡Name: Eric Sensenbrenner
What he does: Eric is the head of Skadden’s Global Tax Group and represents clients on a broad range of U.S. and international tax matters, with a particular emphasis on transactional tax planning in the international context.
Organization: Skadden
Words of wisdom: “You've got to think more about systemic and operational changes.” 
Connect: LinkedIn 
Name: Paul Oosterhuis
What he does: Paul is an internationally recognized senior practitioner in the area of international tax. He has extensive experience in mergers and acquisitions, post-acquisition integration, spin-offs, internal restructuring and joint ventures. He also represents multinational companies in non-transactional international tax planning and assists clients in resolving high-stakes, complex tax controversies.
Organization: Skadden
Words of wisdom: “ I think we all need to just kind of keep our seat belts tight until we see the outcome of the 2024 election to see if we're going to be part of the Pillar two community or if we're gonna be bucking the Pillar two community.”
Connect: LinkedIn 
Connect with Skadden☑️ Follow us on Twitter & LinkedIn.
☑️ Subscribe to GILTI Conscience on Apple Podcasts, Spotify, Google Podcasts, or your favorite podcast app.
☑️ Let us know what topics you would like to hear about on GILTI Conscience by emailing our executive producer at eman.cuyler@skadden.com.
GILTI Conscience is a podcast by Skadden, Arps, Slate, Meagher & Flom LLP, and Affiliates. Skadden’s tax team is recognized globally for providing clients with creative and innovative solutions to their most pressing transactional, planning, and controversy challenges. The insights and views presented in...

Pro bono projects provide unique flexibility and opportunities for skill development, benefiting both the professional who takes on the work and the client. 
In this episode of “GILTI Conscience,” hosts David Farhat, Stefane Victor and Nate Carden present the next installment of the podcast’s Spotlight Series, which includes a discussion with associates Jared Binstock and Sanessa Griffiths about the role pro bono work plays in tax and their experiences and motivations behind taking on this type of work.
Both Sanessa and Jared provide examples of how to find pro bono projects that are a good fit for their practices. For Sanessa, finding causes that are aligned with her values and interests motivate her to say yes. Jared explains, "If I have time to work on it, I usually just say yes. I'm not picky because you never really know what issues are going to come up. It's always a learning experience."
💡 Featured Guests 💡Name: Sanessa Griffiths
What she does: Sanessa advises clients on a broad range of tax controversy matters and transactional situations. Her practice focuses on matters related to high-stakes and complex tax controversies involving transfer pricing, economic substance and business purpose doctrines, and tax treaty interpretation. 
Organization: Skadden
Words of wisdom: “There are so many things you can do in pro bono, even within just the realm of tax pro bono, that'll make you a better lawyer while contributing to society.” 
Connect: LinkedIn 
Name: Jared Binstock
What he does: Jared advises on the tax aspects of debt and equity financings, initial public offerings, bankruptcy restructurings, and internal integration and restructuring transactions. In addition to his broad-based M&A tax practice, he counsels clients in the financial services sector on insurance-related corporate transactions, including capital raising, reinsurance transactions and restructurings.
Organization: Skadden
Words of wisdom: “One of my favorite parts about practicing tax has been the experience that I've had in pro bono.” 
Connect: LinkedIn
Connect with Skadden☑️ Follow us on Twitter & LinkedIn.
☑️ Subscribe to GILTI Conscience on Apple Podcasts, Spotify, Google Podcasts, or your favorite podcast app.
☑️ Let us know what topics you would like to hear about on GILTI Conscience by emailing our executive producer at a...