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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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The Evolution and Impact of the CWI Standard
Episode 38
Wednesday, 25 March, 2026
In this episode of "GILTI Conscience," Mike McDonald, one of the architects of Internal Revenue Code Section 482, joins Skadden’s Nate Carden, David Farhat, Eman Cuyler and Stefane Victor for an in-depth discussion of the "commensurate with income" (CWI) standard. The panel explores the legislative history and intent behind CWI, its complex relationship with the arm’s length principle and the evolution of regulatory approaches.💡 Featured Guests 💡Name: Mike McDonaldWhat he does: Mike spent 16 years at the U.S. Department of the Treasury in the business and international tax division, followed by a career as managing director of international tax and transactions, transfer pricing at Ernst & Young. He was a drafter of the Section 482 transfer pricing regulations, including 482-7.Words of Wisdom: "The fact that, to the extent that a ‘pure hindsight rule’ is going to be applied, then there is going to be wicked double taxation, because the other side doesn't have to respect it.”Connect: LinkedInConnect with Skadden☑️ Follow us on X and 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 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.
