by Skadden, Arps, Slate, Meagher & Flom LLP
This is GILTI Conscience: Casual Discussions on Transfer Pricing, Tax Treaties, and Related Topics, a podcast from Skadden that invites thought leaders and industry experts to discuss pressing transfer pricing issues, international tax reform efforts, and tax administration trends. We also dig into the innovative approaches companies are using to navigate the international tax environment and address the obligation everyone loves to hate. If you like what you’re hearing, be sure to subscribe in your favorite podcast app so you don’t miss any future conversations. Skadden's tax team is recognized globally for providing clients with creative and innovative solutions to their most pressing transactional, planning, and controversy challenges. Additional information about Skadden can be found at 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. This podcast is provided for educational and informational purposes only and is not intended and should not be construed as legal advice. This podcast is considered advertising under applicable state laws.
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March 25, 2025
<p>When goods, services and rights go back and forth within a company, how do you attribute profit or loss to one part of the company versus another? Former OECD head of tax treaties and transfer pricing Mary Bennett and EY’s Mike McDonald join this episode of “GILTI Conscience” for a detailed discussion on the attribution of profits to permanent establishments. Skadden tax partners <a href="https://www.skadden.com/professionals/f/farhat-david" rel="noopener noreferrer" target="_blank">David Farhat</a> and <a href="https://www.skadden.com/professionals/c/carden-nathaniel" rel="noopener noreferrer" target="_blank">Nate Carden</a> and associate <a href="https://www.skadden.com/professionals/v/victor-stefane" rel="noopener noreferrer" target="_blank">Stefane Victor</a> host the discussion, which explores, among other topics, critical differences between Articles 7 and 9 of the OECD Model Tax Convention and why these distinctions matter for multinational businesses. </p><h2>💡 Featured Guests 💡</h2><p><strong>Name:</strong> Mary Bennett</p><p><strong>What she does: </strong>Mary worked in private practice before joining the Office of International Tax Council at Treasury. She spent six years as the head of tax treaties and transfer pricing at the OECD in between two stints as a partner at Baker McKenzie before retiring in 2022.</p><p><strong>Organization: </strong>Formerly <a href="https://www.oecd.org/" rel="noopener noreferrer" target="_blank">OECD</a> and <a href="https://www.bakermckenzie.com/" rel="noopener noreferrer" target="_blank">Baker McKenzie</a></p><p><strong>Words of wisdom:</strong> "The AOA recommends that companies create internal documentation of how their situations should be characterized, and countries should follow that documentation unless it clearly doesn't reflect reality.”</p><p><strong>Connect: </strong><a href="https://www.linkedin.com/in/marybennettdc/" rel="noopener noreferrer" target="_blank">LinkedIn</a></p><p><strong>Name</strong>: Mike McDonald</p><p><strong>What he does</strong>: Mike spent multiple stints at Treasury and EY, currently serving as managing director of International Tax and Transactions,Transfer Pricing at EY.</p><p><strong>Organization: </strong><a href="https://www.ey.com/en_us" rel="noopener noreferrer" target="_blank">EY</a></p><p><strong>Words of Wisdom</strong>: “I think the best primer on profit attribution in general is Chapter One, or Part One, of the AOA.”</p><p><strong>Connect</strong>: <a href="https://www.linkedin.com/in/michael-mcdonald-980aa433b/" rel="noopener noreferrer" target="_blank">LinkedIn</a></p><h2>Connect with Skadden</h2><p>☑️ Follow us on <a href="https://twitter.com/SkaddenArps?ref_src=twsrc%5Egoogle%7Ctwcamp%5Eserp%7Ctwgr%5Eauthor" rel="noopener noreferrer" target="_blank">X</a> and <a href="https://www.linkedin.com/company/skadden-arps-slate-meagher-flom-llp-affiliates/" rel="noopener noreferrer" target="_blank">LinkedIn</a>.</p><p>☑️ Subscribe to GILTI Conscience on <a href="https://podcasts.apple.com/us/podcast/gilti-conscience/id1603270987" rel="noopener noreferrer" target="_blank">Apple Podcasts</a>,<a href="https://open.spotify.com/show/3nNf0ip6ooZ6ilbhpBJ4lR" rel="noopener noreferrer" target="_blank"> Spotify</a> or your favorite podcast app.</p><p>☑️ Let us know what topics you would like to hear about on GILTI Conscience by emailing our executive producer at <a href="mailto:[email protected]" rel="noopener noreferrer" target="_blank">[email protected]</a>.</p><p>GILTI Conscience is a podcast by <a href="https://www.skadden.com/" rel="noopener noreferrer" target="_blank">Skadden, Arps, Slate, Meagher & Flom LLP, and Affiliates</a>. 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...
September 4, 2024
<p>Amount B is designed to streamline transfer pricing for baseline distribution and marketing companies worldwide, but “we’re apparently in a world of complexity and controversy,” says <a href="https://kpmg.com/us/en/how-we-work/people/c/coleman-jessie.html" rel="noopener noreferrer" target="_blank">Jessie Coleman</a>..</p><p>A principal at <a href="https://kpmg.com/us/en.html" rel="noopener noreferrer" target="_blank">KPMG</a>, Jessie joins Skadden attorneys Nate Carden, David Farhat, Eman Cuyler and Stefane Victor to discuss everything there is to know about the current and future status of Amount B. Together, they explore questions of scoping – will jurisdictions agree that an entity is in-scope? – and who’s signing on to Amount B, as well as tensions that may arise over how to handle disputes. </p><p>For companies that would likely be in-scope when implementation launches, Jessie suggests they prepare by monitoring their assets-to-sales, which will drive where they fit in the Amount B matrix. “I think knowing the unknown right now is really important,” she observes. </p><h2>💡 Featured Guests 💡</h2><p><strong>Name: </strong><a href="https://kpmg.com/us/en/how-we-work/people/c/coleman-jessie.html" rel="noopener noreferrer" target="_blank">Jessie Coleman</a> </p><p><strong>What she does: </strong>Jessie provides services related to transfer pricing planning, documentation, and controversy and international tax policy.</p><p><strong>Organization: </strong><a href="https://kpmg.com/us/en.html" rel="noopener noreferrer" target="_blank">KPMG</a></p><p><strong>Words of wisdom: </strong>“It's pretty important that companies look at where they are right now and also make sure that there's no misclassifications, I would say, or confusions. I think knowing the unknown right now is really important.”</p><p><strong>Connect: </strong><a href="https://www.linkedin.com/in/jessie-coleman-10bb03/" rel="noopener noreferrer" target="_blank">LinkedIn</a> </p><h2>Connect with Skadden</h2><p>☑️ Follow us on <a href="https://twitter.com/SkaddenArps?ref_src=twsrc%5Egoogle%7Ctwcamp%5Eserp%7Ctwgr%5Eauthor" rel="noopener noreferrer" target="_blank">X</a> and <a href="https://www.linkedin.com/company/skadden-arps-slate-meagher-flom-llp-affiliates/" rel="noopener noreferrer" target="_blank">LinkedIn</a>.</p><p>☑️ Subscribe to GILTI Conscience on <a href="https://podcasts.apple.com/us/podcast/gilti-conscience/id1603270987" rel="noopener noreferrer" target="_blank">Apple Podcasts</a>, <a href="https://open.spotify.com/show/3nNf0ip6ooZ6ilbhpBJ4lR" rel="noopener noreferrer" target="_blank">Spotify</a>, or your favorite podcast app.</p><p>☑️ Let us know what topics you would like to hear about on GILTI Conscience by emailing our executive producer at <a href="mailto:[email protected]" rel="noopener noreferrer" target="_blank">[email protected]</a>.</p><p><em>GILTI Conscience is a podcast by </em><a href="https://www.skadden.com/" rel="noopener noreferrer" target="_blank"><em>Skadden, Arps, Slate, Meagher & Flom LLP, and Affiliates</em></a><em>. 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.</em></p>
July 17, 2024
<p>In our second episode in our spotlight series focused on celebrating diversity, GILTI Conscience’s <a href="https://www.skadden.com/professionals/f/farhat-david" rel="noopener noreferrer" target="_blank">David Farhat</a> and <a href="https://www.skadden.com/professionals/v/victor-stefane" rel="noopener noreferrer" target="_blank">Stefane Victor</a> are joined by colleagues <a href="https://www.skadden.com/professionals/b/breheny-brian-v" rel="noopener noreferrer" target="_blank">Brian Breheny</a> and <a href="https://www.skadden.com/professionals/s/schwartz-jordan-m" rel="noopener noreferrer" target="_blank">Jordan Schwartz</a> for an earnest dialogue on DEI in big law. The guests discuss some of the challenges they faced as gay professionals, including their experiences coming out at work and questions they faced, as well as their efforts to advocate for diversity in the workplace and embrace its importance.</p><h2>💡 Featured Guests 💡</h2><p><strong>Name:</strong> <a href="https://www.skadden.com/professionals/b/breheny-brian-v" rel="noopener noreferrer" target="_blank">Brian Breheny</a> </p><p><strong>What he does: </strong>Brian Breheny is a partner and co-head of Skadden’s SEC Reporting and Compliance practice. Brian formerly held numerous leadership positions at the SEC leader and now concentrates his practice on mergers and acquisitions, corporate governance, and general corporate and securities matters.</p><p><strong>Organization: </strong> <a href="https://www.skadden.com/" rel="noopener noreferrer" target="_blank">Skadden</a></p><p><strong>Words of wisdom:</strong> “Keep in mind what you think people are thinking of you and be careful to address that — not to fix your personality to meet what you think they need.”</p><p><strong>Connect: </strong> <a href="https://www.linkedin.com/in/brian-v-breheny/" rel="noopener noreferrer" target="_blank">LinkedIn</a></p><p><strong>Name:</strong> <a href="https://www.skadden.com/professionals/s/schwartz-jordan-m" rel="noopener noreferrer" target="_blank">Jordan Schwartz</a></p><p><strong>What he does:</strong> As counsel in Skadden’s Mass Torts, Insurance and Consumer Litigation Group, Jordan Schwartz represents clients in purported class actions, multidistrict litigation and mass tort proceedings in federal and state courts. </p><p><strong>Organization: </strong> <a href="https://www.skadden.com/" rel="noopener noreferrer" target="_blank">Skadden</a></p><p><strong>Words of wisdom: </strong>“I think it's really incumbent on us to highlight how enjoyable [DEI efforts are], how enriching the experience is. That’s why we have a Diversity Committee.”</p><p><strong>Connect: </strong> <a href="https://www.linkedin.com/in/jordanmschwartz/" rel="noopener noreferrer" target="_blank">LinkedIn</a></p><h2>Connect with Skadden</h2><p>☑️ Follow us on <a href="https://twitter.com/SkaddenArps?ref_src=twsrc%5Egoogle%7Ctwcamp%5Eserp%7Ctwgr%5Eauthor" rel="noopener noreferrer" target="_blank">X</a> & <a href="https://www.linkedin.com/company/skadden-arps-slate-meagher-flom-llp-affiliates/" rel="noopener noreferrer" target="_blank">LinkedIn</a>.</p><p>☑️ Subscribe to GILTI Conscience on<a href="https://podcasts.apple.com/us/podcast/gilti-conscience/id1603270987" rel="noopener noreferrer" target="_blank"> Apple Podcasts</a>,<a href="https://open.spotify.com/show/3nNf0ip6ooZ6ilbhpBJ4lR" rel="noopener noreferrer" target="_blank"> Spotify</a> or your favorite podcast app.</p><p>☑️ Let us know what topics you would like to hear about on GILTI Conscience by emailing our executive producer at <a href="mailto:[email protected]" rel="noopener noreferrer" target="_blank">[email protected]</a>.</p><p><em>GILTI Conscience is a podcast by</em><a href="https://www.skadden.com/" rel="noopener noreferrer" target="_blank"><em> Skadden, Arps, Slate, Meagher & Flom LLP, and Affiliates</em></a><em>. Skadden’s tax team is recognized globally for providing clients...
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