In our second episode in our spotlight series focused on celebrating diversity, GILTI Conscience’s David Farhat and Stefane Victor are joined by colleagues Brian Breheny and Jordan Schwartz 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.

Name: Brian Breheny

What he does: 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.

Organization: Skadden

Words of wisdom: “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.”

Connect: LinkedIn

Name: Jordan Schwartz

What he does: 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.

Organization: Skadden

Words of wisdom: “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.”

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...

“You want people to be themselves. You're going to get the most productivity, the most career longevity from somebody that's happy about being where they are,” says De Lon Harris.

In celebration of Pride Month, Skadden 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 the IRS and the different roles he took on, as well as his experience as a gay person working in government service. He also touches on mentorship, including the importance of seeking diversity in mentors.

Name: De Lon Harris

What he does: De Lon Harris is the Senior Advisor for Tax Resolution Strategies at Skadden. With more than three decades of experience at the IRS, De Lon Harris counsels clients on a wide range of tax controversy matters.

Organization: Skadden

Words of wisdom: “You can't truly be happy if you're not comfortable in the workplace or you're not being exactly who you need to be.”

Connect: LinkedIn

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☑️ Subscribe to GILTI Conscience on Apple Podcasts, Spotify 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.

“Transfer pricing, itself, is more of an art than a science. There's a lot of gray area in many, many aspects of transfer pricing,” says Clark Armitage.

In this episode of the “GILTI Conscience” podcast, Skadden attorneys Nate Carden, David Farhat, Eman Cuyler and Stefane Victor, are joined by guest Clark Armitage of Caplin & Drysdale. The group dives into a comprehensive discussion about the intricacies of ICAP, MAP and APA in cross-border transfer pricing issues. They consider the application of each as a tool, debating their benefits and potential drawbacks in aiding taxpayers.

The panel also discusses how a Pillar Two-world could bring additional questions to already complex pricing practices.

Name: J. Clark Armitage

What he does: Clark Armitage is a member at Caplin & Drysdale with vast experience in international tax lawyer with a focus on transfer pricing.

Mr. Armitage's core practice is advising multinational corporations from a wide range of industries on transfer pricing matters, including planning, audits and appeals, advance pricing agreements (APAs) and mutual agreement procedures (MAPs). He has a particularly strong background in APAs, having served eight years in the IRS Advance Pricing Agreement Program, including as deputy director from 2008-10.

Mr. Armitage also advises clients on other U.S. international tax issues. He is well versed with issues arising under the Tax Cuts and Jobs Act of 2017, including GILTI, FDII, BEAT and foreign tax credit basketing. He represents clients with residency issues before the IRS Treaty Assistance and Interpretation Team (TAIT), helps clients navigate the U.S. federal income tax implications of bona fide Puerto Rican residency and status under Puerto Rico Act 20, Act 22, Act 60 and Act 73, and advises on permanent establishment and similar exposures.

Organization: Caplin & Drysdale

Words of wisdom: “The MAP process is based on bilateral treaties, for the most part bilateral, between two countries that allow for two competent authorities to come together to resolve a transfer pricing dispute.”

Connect: LinkedIn | Email

☑️ Follow us on Twitter & LinkedIn.

☑️ Subscribe to GILTI Conscience on Apple Podcasts, Spotify 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...