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.

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.

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.”

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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.

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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☑️ 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.