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GILTI ConscienceCasual Discussions on Transfer Pricing, Tax Treaties, and Related Topics Author: 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 youre hearing, be sure to subscribe in your favorite podcast app so you dont 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. Skaddens 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. Language: en Genres: Business, Government, Investing Contact email: Get it Feed URL: Get it iTunes ID: Get it Trailer: |
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From GILTI to NCTI: Unpacking the 2025 Tax Overhaul
Episode 36
Thursday, 13 November, 2025
This podcast’s title hasn’t changed, but on the international tax stage GILTI is converting to the new CFC-tested income (NCTI) regime.That’s just one shift brought about by the One Big Beautiful Bill that Congress passed on July 4. Skadden colleagues Loren Ponds, Eric Sensenbrenner and Paul Oosterhuis break down the bill’s implications in this conversation with David Farhat and Stefane Victor. The panel explores the legislative process, the impact of dropped provisions such as Section 899 and key planning considerations. Tune in for their insights about how corporate stakeholders can navigate the new landscape.💡 Featured Guests 💡Name: Eric SensenbrennerWhat he does: Eric 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: SkaddenWords of wisdom: “FDII is now becoming a much more interesting and much more robust tool for attracting investment, both for multinationals thinking about bringing assets back as well as perhaps for inbound investment as well.”Connect: LinkedInName: Loren PondsWhat she does: Loren leverages her extensive tax policy experience to provide strategic counsel to clients across industries on a variety of legislative and regulatory issues.Organization: SkaddenWords of wisdom: “I can speak from experience working on the Hill: When you think you're gifting taxpayers something in a provision, and all you get is pushback, it becomes very easy for that provision to disappear from the final bill, particularly when we're talking about the cost, in addition to the poor reception.”Connect: LinkedIn Name: Paul OosterhuisWhat he does: Paul is an internationally recognized senior tax practitioner with extensive experience in cross-border mergers and acquisitions, post-acquisition integration, spin-offs, internal restructurings and joint ventures.Organization: SkaddenWords of wisdom: “From my perspective, maybe the Trump administration should be talking to those countries about being more lenient in allowing U.S. companies to bring back their IP. Maybe they could get breaks on their tariffs, for example, if they decided to suspend their rules on U.S. companies bringing back their IP.”Connect:...
