In this episode of the “GILTI Conscience” podcast, longtime Skadden tax partner Fred Goldberg joins our hosts Nate Carden and David Farhat to discuss his one-of-a-kind journey through the public and private tax sectors. Fred details the changes he’s seen, his hopes for the future of the field and his advice for those looking to begin a career in tax law.

As Fred notes, the tax system is the one set of regulations that every individual, family, business and nonprofit in the country must contend with each year. And for each, the challenge is the same: When you get your taxes right, everything is fine, but when you get them wrong, havoc ensues. 

Many people who might consider a career in tax law are driven away by misconceptions about the work — e.g., a tax attorney can’t be altruistic or give back to society. However, Fred believes tax is not just transactional — it’s also relational: The field presents opportunities to collaborate, chase your passion and connect with others. The profession also needs a wide range of personalities and perspectives — you don’t have to change yourself to fit some preconceived notion of an ideal tax attorney. A career in the tax field requires only creativity, listening skills and authenticity. 

Fred hopes that mentorship, education and a willingness to shift perspectives can enable tax law to become more diverse and inclusive. He regularly shares the same advice with aspiring lawyers, young professionals already in the tax sector and people on the street: Tax law can make for an outstanding career. 

💡 Featured Guest 💡

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. 

Words of wisdom: “Saying it's easy, doing it's hard, but that's why the career is so wonderful. No matter who you are, how you think, what you care about, whether you go into it hammer and tong in a big fight, or whether you like three-dimensional chess, whatever turns you on, it is a spectacular profession.”

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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.

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. Now your hosts, Skadden partners David Farhat and Nate Carden.

Hi everybody. Welcome back to another episode of GILTI conscience. I'm Nate Carden. As always, I'm joined by David Farhat and Stefane Victor. Amon is still on leave, and so we're joined by Jaclyn Roeing as our guest host. Jaclyn, why don't you introduce yourself?

Hey, there everyone. My name is Jaclyn Roeing. I'm an associate in the tax group of Skadden Arps in our Washington DC office. I'm really excited to be here today with you all. Thanks for the invitation.

Today, we're going to continue our series on careers in tax, and we're joined by somebody who, it is no exaggeration to say, probably has had the most illustrious career in the history of United States tax. It is a great honor to have Fred Goldberg. He's served in virtually every senior government role that there is in tax, including as commissioner. We've also had the privilege of having him as a partner here for many years. Fred, welcome. Thanks so much for joining us, and I guess let's start with how'd you get into tax.

Well, Nate, I should start by saying I'm real old, so we're going way back in history here, but I started law school in the fall of 1969. I hated it, and I dropped out, and I called an economics professor that I'd had in college, who had moved to Washington DC and was working in the government. So I called him and said, "Hey John, can you get me out of here?" He says, "Sure. You're hired." "Oh great. I'm coming." He said, "Well, you've got to get rid of your ponytail. You've got to buy a suit. You've got to buy some real shoes," and I said, "No problem," and he said, "You've got to register as a Republican," and I said, "Oh, whatever, get me out of here." So in 1970, in January, I moved down to Washington DC and went to work for him as his special assistant at the office of economic opportunity.

Richard Nixon's senate one, his highest legislative priority, thanks to Pat Moynihan, was the family assistance plan. Family assistance plan was the negative income tax. Family assistance plan today is universal basic income. So I spent a year learning about the negative income tax, and also learning about what kind of difference it can make in the lives of working poor. So I... Tax was really cool. So I go back to law school. My father had told John that if I didn't go back in a year, he was going to kill John. Better to kill at me, so I went on back to law school, took a class from a guy named Boris... Professor Bicker. One question on the final exam discussed the negative income tax. So God had picked up her megaphone and said, "Kid, go be a tax lawyer."

So I follow orders, so there you go. That's how I ended up being a tax lawyer, but it was important, because I learned at 22 that the tax law matters, and it matters a lot, and I've loved it ever since.

So give us a little bit more on that, Fred, because I think when you say the tax law matters and it matters a lot, I think a lot of folks in tax law and tax can understand that or relate to it, but unpack that a bit for maybe some of our younger listeners or students who are kind of just curious about tax.

Sure, David. The tax system is the one thing, the only thing in our country that every single one of us, every individual, every family, every big business, every small business, person running the estate for a dead person, nonprofits, we've all got to deal with it every year. Now, it may be nothing more than deciding you don't have to file. It may be you're a giant multinational company dealing with taxes globally. Maybe you're a church. Everybody touches it, has to touch it every year, and that's a pretty daunting picture, because when you get it right, that's great. When you get it wrong, it's a giant mess.

Fred, I think you raise a really interesting point about taxes, which is that the way in which it impacts people's lives on a day to day basis is much different than the way tax is taught in law school. I think that connecting tax to the people who are behind those tax returns and the companies behind them is really important.

That's so right, Jaclyn, and the IRS is in a lot of issues right now, because they're 30 million returns behind in processing. So you paint this picture of a bunch of 1040s sitting on a table saying, "Please process me, please process me." No, there's a human being behind every single one of them, and when you get a letter from the IRS, you've got to deal with it. When you're trying to develop cross border supply chains, you've got to deal with it, except you've got to deal with a bunch of governments, not just one, and it's a fascinating process, but for many of us, we're really interested in those cross border supply chains, transfer pricing, gilty, which doesn't have a U in it, for this purpose, but there are all those folks out there who don't have the resources, who don't have the ways to navigate.

My main focus at this point in my career tends to be low income individuals, struggling communities. I still do it at the high end, folks trying to get out of Russia today. Saying it's easy, doing it's hard, but that's why the career is so wonderful. No matter who you are, how you think, what you care about, whether you go into it hammer and tong in a big fight, or whether you like three dimensional chess, whatever turns you on, it is a spectacular profession.

So Fred, let me use that hook to talk about your career a little bit, and I want to come to the work you're doing now, especially around kind of low income folks, but you talked a little bit about how you developed this passion for tax and how you got the calling for tax. What happened next? Kind of walk us through the career, how you went to the IRS, became commissioner, worked at treasury, worked at chief council, got to Skadden. Can you kind of walk us through that and kind of get us to where you are now and a lot of the work you're doing now?

Sure, David. The starting point is I had my first mentors when I was in high school. Some of them were my same age, and I think all of us, our careers happen not in a vacuum. They happen in terms of how we grew up. I grew up in St. Louis. St. Louis is a very challenging city to grow up in, but everybody who comes in contact with you influences the path. In my particular case, I would say the guiding principal was impulse. I proposed to my wife in 13 day... I'd already dropped out of law school. I was going to move to St. Louis, live on a farm, teach, but then got a chance to go to DC with the firm I was with. Made partner at the firm I was with, Latham & Watkins. Quit to go work in the government as an assistant to the commissioner. As a 74 year old guy, it's not the planning, it's seeing the opportunities and taking the chances. That's been my experience, and at least for me, it's worked great.

But in terms of what I'm doing now, I love high end tax. I do it on the controversy side, not on the planning side, and it's fascinating. I don't see it as much as a game as some people do, because I think it's real, but the tax system...

I was on a call earlier today, the group called Tipping Point and a west coast city government. Here was the question. "We want to give cash to folks who are at risk of being evicted, or who are already homeless. We can't do it, because that's taxable." Well, no, it's not taxable. Virtually every project I touch, whether it's about early childhood education, whether it's funding for college, whether it's dealing with substandard housing, which affects environment, health, safety, family wellness, they always get to the tax, and if you think that capital drives pretty much everything, the capital to go to school, the capital to create a multinational company, the capital to promote whatever it is you care about, it will have tax consequences. Those tax consequences can make it work better. Those tax consequences can make it work or not work at all. So it's just pick what interests you and go do it, is my view.

So I want to touch on something quickly, Fred, and you're talking about how tax is everywhere and everything touches tax. For me, one of the... Law school, kind of fell in love with tax, really wanted to do it, but one of the issues for me was it felt like, for lack of a better term, kind of selling out. You're going to do tax, you're not with the people anymore. You're now doing something corporate, something that's completely removed from doing any kind of good, right? As you kind of described it before, a lot of folks look at it as kind of playing a game. You're just playing with money and you're trying to play keep away with the government. What's your advice to young people who want to go into tax, but also have an altruistic streak or who want to do something for society, who want to give back?

The most fascinating thing, in some ways, to me, is first of all, what we do, lawyering, is a talent process. It's not some high end fab plant. We walk in the door, walk out the door, or practice remote, and it turns out, particularly among the younger lawyers we try to recruit, yeah, they want to learn their craft. Yeah, they want to make money to pay off their outrageous student debts. They also want to work in diverse communities where they can also chase their passions.

Jaclyn and I worked on tax controversy work. Well, I'm very involved in this issue about how you get low income tax payers tax credits and benefits. Well, it turns out Jaclyn's been doing that for six years. We are now working for this terrific group called Code for America that just got a hundred million dollar grant, because they use technology to get folks what they're supposed to be getting from the government. They do a technology based expungement of criminal records, they're doing other benefits in addition to tax, and here is this person, Jaclyn, who really knows this stuff. She's been doing it. We're now working together on this, and one of the joys of lawyering is when it's human folk working together, not just transactional.

So you talk about the ubiquity of tax. What do you think is keeping the people most in need away from digging in and getting the help that they need through the tax code, or alternatively, what do you think is keeping diverse attorneys away from pursuing a career in tax?

Stefane, that's a terrifically important point. Tax is the least diverse field of lawyering among our peer group law firms, and part of it is the perception of tax is making rich people in power positions richer and more powerful. Why do I want to spend my time doing that?

I think the answer to that, in part, is that they've got to live with the system, they've got to make the system work, we've all got to do that, we've got to contribute to making it work, but the other answer is, in the large firm practice of law, there are opportunities to chase your passion. If it's about income inequality, if it's about access to low income, vulnerable communities, if it's about those who have lived with our nation's legacy, that the tax system can address them, and what's wonderful about large law firms is we are powerful institutions, in both what we know how to do and how we do it.

All law firms say, "We believe in diversity, we do believe in pro bono, yay, yay, yay, yay," but young lawyers want truth, they don't want the "yay, yay, yay"s, and you can find out by talking to folks from your age group, peer group, folks who went ahead of you from law school, but it is...

Mayor Adams announced two weeks ago that 65,000 kindergartners in the city of New York now have a scholarship account. Think about that picture. Think about eventually, when it's phased in, a million kids and their families will have these starter scholarship accounts that they can build by families doing their own savings. Well, we were part of a team, other law firms, the organization that's been working on that for seven years.

That's what we get to do. We also get to figure out how companies can get out of Russia. We also get to do things like figuring out how to resolve pricing disputes involving multiple governments. We also get to think about... It's not just the transfer pricing. Talk to Nate Carden for 10 minutes, and you realize it's also about supply chain. Talk to David, and you know it's about how governments interact, as well as private actors interact. This is what we get to do, but to say... There were a bunch of young lawyers at Skadden who worked on that New York City program. They know. They know that our lawyering was part of a big team effort that made a dream, a picture, a vision, a reality, and tax is there just like everywhere else, but so is corporate, so is nonprofit law, so is contract law, and you need to learn your craft, you've got to master your craft, but you can deploy that craft in that direction, as well as other directions.

So Jaclyn, let's talk about the project you're working on with Fred. So it's the summer, right? We have summers coming in. If I'm a summer and I'm a law student, and I'm like, "Hey Jaclyn, I heard GILTI Conscience and you're working on this project, and I heard we had to reach out to attorneys." One, tell us a little bit about the project, your passion for it and how you got to do it while you're at Skadden, kind of juggling all the hours and things of that nature.

To keep my connection to tax alive while I was clerking, I decided to volunteer with VITA, which I believe stands for the Voluntary Income Tax Assistance program, which is run out of the... Well, funded, I should say, by the IRS, but it's not run by the IRS. It's a way to put money into local organizations that then train volunteers to help prepare taxes for low income individuals, and as Fred had mentioned, I've been doing that for... I think it's six seasons now, both as a preparer and as a reviewer. It's always this two step process to make sure the returns are prepared correctly, and so as a result of me being engaged in that work, and then Fred got involved separately with Code for America, which is an organization that, I think, in 2019, launched an online platform called Get Your Refund, and that's a really wonderful platform that connects taxpayers who are remote with, through the virtual space, a vital organization to help prepare their taxes.

What Code for America found was that there were a lot of taxpayers coming to the portal, but they were getting stuck at the stage of getting all their documents uploaded, sharing all of the right information, and as a result, these taxpayers couldn't proceed through the process of getting their returns prepared, and so we connected on this, and I was really excited to see an opportunity for... We were initially pitching to attorneys, but others in the community to get involved with this role, and from there and working kind of the volunteer opportunity, my work has shifted into continuing to advise Code for America on the tax implications of some of their other projects. Right now, we're really excited about the Get CTC portal, which uses a simplified filing method that the IRS announced earlier this year that allows taxpayers, who wouldn't otherwise have a filing requirement to file a normal 1040, to file a simplified tax return that still gets them access to refundable credits like the child tax credit and the economic impact payments.

Awesome.

Jaclyn, I'm curious, from your perspective, doing all this work, how much of this is just a resource issue, more resources are needed, whether it's VITA or other programs... How much of it is a policy issue that we've created a labyrinth of rules for folks who are, generally speaking, lower income folks to try to navigate their way through, and is there anything that we can do to try to make that process simpler by making policy changes?

Yeah. I think that under the current system, there's a huge resource issue. Low income taxpayers don't have the time to talk to an accountant, they don't have the money to pay for it. They might have to take an extra bus or a metro to get there. They need childcare, then, at home, if the kids have to stay home alone. They need to get their documents, they don't have great document storage, they may not have a personal computer to store things. The list of resource issues goes on and on, but I think there's also a lot of policy questions, as well, as to what is the IRS and the federal government doing to make it easier for low income individuals to access their tax benefits.

Fred, do you have some thoughts on tax policy issues that could help improve the situation for low income tax payers?

A few, but what I want to say is the modest Jaclyn has not yet said the Code for America is sponsoring a program this week that will be probably 1500 government officials, practitioners, advocacy groups, and Jaclyn is moderating a panel on that topic.

Awesome.

I'm lucky enough to be on the panel. The other person on the panel is a woman named Julia, who is the chief policy advisor to the mayor of Philadelphia and the deputy chief of staff.

This is absolutely awesome, kind of talking about careers and all the varied things you can do in tax, even at a law firm. You can actually do good for the world while working at a law firm. Go figure.

So thinking about that, I want to ask, how, Fred and Jaclyn, does this kind of go into the topic of mentoring? I think my career has been directed, and I wouldn't be where I was today without mentors. So I can see, as you're describing listening, you guys have a passion for similar work, you end up working together, and a mentorship opportunity could come out of that. So can you guys talk a bit, or Fred primarily, can you talk a bit about the role of mentoring in a tax career and, one, how that can come about, and the importance of it?

I don't know, Nate. Why don't you talk about mentors?

Well, first of all, I just want to say thank you for reiterating the point that I feel like I often have to make, which is if somebody's not understanding the advice you're giving, that's an advisor problem, not a listener problem. I think it's something that people need to keep in mind, but I guess, extending on what you're saying, I think that so much of this really does boil down to how to work. What are you looking for in a career? How can you build the set of tools that makes you professionally satisfied and personally okay, and balancing all those things? None of which has anything to do with cracking the internal revenue code, but I am curious, especially as I think about my own role as a mentor to some other folks and helping them think about building careers, you have navigated back and forth between public service and private practice, and for those out there who are starting their careers, people who are thinking about, "Hey, I've got a lot of student debt to pay. Hey, I'm thinking about my career at a law firm or other private professional services organization." How do you advise people in when to think about pursuing public service, and also, why? What's a good reason? What's not a good reason to decide to go work for the government?

Both my experience and my observation is that, for some folks, starting in the government is a good way to go. The reality of large law firms is the path starting with the government and then making it into high level law firms. There are not a lot of people who can do that. David's one... No, actually you started in the private sector, didn't you, David? But the private sector...

Dave's a special case.

In so many ways we can't begin to count, but Nate...

Bringing private sector practice experience into your time in the government lets you do a better job in the government, because you've seen it, and the motives for the government is public service. I think it's a very real, honest motive. A motive that says that I can enhance my career options. I think that's accurate. It's not... Say, good... "No, no, no. You can only do it if you want to be a saint or something," is not accurate.

One of the things that fascinates me is, "What kind of lawyer do you want to be, person you're interviewing?" "I want to be an international lawyer." "Okay. Tell me more." There's so many different places to be an international lawyer. You can do litigation, you can do dispute resolution, you can do transactional work, you can do internal planning and structuring work, you can do policy work, and that's true of each of these areas, and so finding what works is not just the subject matter, it's who you are, because the personality of a litigator versus the personality of someone who thinks we should all be lovey and resolve disputes is different. Internal structuring, internal planning.

The relationship with the client, the actors in that process, are very different from the actors in a process where you're trying to negotiate a transaction, and again, it comes back to my view that the tax profession is a very special place in terms of... It works for your personality. Your personality does not have to become what works as a tax lawyer, and I think that's a big deal.

Mentoring. How do I turn on and off my computer? How do I do my... There's sort of the mechanics of being a lawyer that are very important. When I was a first year, second year associate, a lawyer... Firm I was at took me out for lunch. He told me which fork to use, because I had no idea why I had two or three forks sitting in front of me, and there is also the navigation, because we all come from different places. Then there's the transactional, writing a document, writing a memo, drafting, whatever, and then there's the, "How do I feel about this?" What about, "I really want to do some public service," or, "I am going to suck it up, grind it out, I'm going to be here for the rest." There is that. So the mentoring happens in all of those dimensions.

"I am uncomfortable with how I am being treated at this institution." Maybe because of my gender, maybe because of my race, maybe because of my orientation, maybe because of where I grew up, maybe because of the economic circumstances I grew up in, and we all bring that, every one of us, and that kind of mentoring that connects with the person and embraces it, because there are no rights and wrongs, it's just life, and that kind of mentoring cannot be programmed or taught. It just kind of happens, and in some ways, the others are important. That one's important as well. I don't know if... David, but that's how at least I think about mentoring.

No, I really appreciate it, and I really appreciate the point about not adjusting your personality to do something in tax, but doing something that your personality lends you to. I think that's important about people being in the practice and being authentic, and being able to feel like themselves or feel like they belong, and I think that's a big part of belonging. Folks coming in and not having to change themselves or not having to be something they're not to be successful in the profession.

How would you say that the lack of diversity has either affected your career in tax or... How have you remarked that it's affected tax in general, and over the years, has that improved, and now at Skadden, how would you say that the diversity that we have here currently affects the practice as you can see it?

Stefane, there's a fair amount out there. One could read The Whiteness of Wealth by Professor Brown to understand why a facially neutral tax system embeds historic inequities. You could also understand how the tax system is a powerful tool to address them. One of the things that fascinated me about Skadden was the number of partners who had not gone to Harvard, Yale, Stanford, or Michigan. It was terrific. The number of folks in our community who were first generation professionals, and David, I think the point you made before is so important. It's not abstract words. It is better quality for the client. That's where it lands, and those different perspectives, those different ways of framing, make a difference. It's creativity, it's listening better to what you're hearing.

As Jaclyn was saying before, I view this... In some ways I'm changing transactional, in the sense that we expect young lawyers to work hard and do really great work. Young lawyers have an equal right to an expectation that we invest in them down the roads that they ultimately decide they are comfortable going down. That's the deal, and it's hard for young lawyers. A young lawyer gets an assignment, and you talk to them about it. I didn't understand it, but I was afraid to ask a question, because the supervising authority would think I was an idiot. It's exactly the opposite.

That young lawyer is paying attention and thinking about it. The lawyer who says, "I have not had the experience doing IRS appeals," or, "I've not had the experience doing a cash acquisition," or, "I have not had the experience doing whatever it is you guys have been doing for the last 20, 30 years," that is okay. In fact, it's not just okay, that's the way it should work, but big law firms are a scary place, and part of the mentoring is giving the comfort, the safeness to ask those kind of questions and welcome those, at least that's... Welcome those kind of questions. This is kind of a cheaty panel, because both of you do such a great job of it, but seriously, you both do a great job at it, but you do it different ways, different styles, because that's who you are, and that's good.

I'm curious as to how you think practice has changed in tax from when you started... I feel like it's changed from when I started to what junior lawyers are facing today.

Well, that's kind of a loaded question, because I've got 52 years on that subject, but I'll take that. I think that it has changed in a couple of ways, because I think that... And a lot of this is attributable to market forces. There is a big premium and, in my personal view, a misguided premium on instant specialization, and I think that detracts from how you do your job. The other change is, I think, the tax system, maybe derivative of specializations, drove very much in the direction of literalism in terms of, "Well, this is what this says, and therefore we can," and I don't think that works very well, because you ought to ask... At least I think folks ought to ask, “what should the answer be? What makes sense here now?”

That's not the law, and the fact that it doesn't make sense can present interesting planning opportunities. It can also bring death, destruction and disaster, because it doesn't make sense, but going through the process of saying, "What makes sense here?", is a useful way to go, and I think that the periodic eruptions of "massive tax shelter marketing" was derivative of not stepping back and saying, "Really?", and I think, again, that was, to some extent, derivative of specialization, but then...

I'm a Bruce Springsteen glory days fan, so we can go back to before all this happened, but I think it ebbs and flows, but Nate, those are the two that I would describe. I think the third one is that international... When you look at how much of the US GDP was US developed, generated, created GDP in the early sixties, and you look at how the economy works today, that is an external fact that change is very much what we do, and when you look at the movement from bricks and mortar to intangibles, I would describe those two as the biggest external changes that drive so much of what we do, but I don't know what you and David think are big changes.

Those are certainly biggies. I 100% agree on specialization. I think that... And one of the things I encourage everybody to try to do, is if you live in a state like Illinois, and I think a lot of other states, you need CLE, don't use it to do what you work on every day. Use it to learn areas of the tax law that you don't ever touch, because guess what? You don't need to know it that well, so you're listening to the CLE and you click through, but you pick up things that are analogous to the things that you're working on, and understand why the system works the way it works, and I think it's incredibly useful.

I certainly agree on the international capital flows front. That's sort of what I've kind of built my life around, right? So far be it for me to complain about it, but it's certainly a reality of what's happening. I also wonder... And Jaclyn, maybe I'll throw this to you briefly. How much... Not so much in the kind of work that I do on a day to day basis, but as we think about the tax system, how much is the shift from, I'll call it traditional W-2 employment to 1099 compensation influencing how, particularly people who are lower income folks, are interacting with the tax system, and is it a problem?

I think it's an interesting question, because it's one where the industry for gig work, for self-employment work, is exploding. Not only through things like Uber and Lyft, but also with the pandemic. So many people are moving towards a self-employment model, and the IRS is trying to keep up, but doesn't necessarily have all those solutions. There's guidance to be certain about how income should be reported and how you can report your costs and things, but I know what I've seen with my VITA volunteering work is someone will come in with a shoebox full of receipts, and they have no idea how to take care of their books. What's a class that they can claim for the business versus one that's not? Part of the problem here, though, in terms of looking for the proper administration of the tax laws is thinking about the disjoint between the income information that an individual taxpayer has versus what's reported to the government.

Well, I hate to be the bearer of bad news, but we're coming on time. This is a conversation I could have forever, but Nate, I'll throw it to you for your question, and then maybe kind of go around to see if there are any final thoughts.

I've got one last question for Fred, and really, it's because I'm trying to get my mom to listen to this. She only will if I give her a shout out, so here we go. What's something that you think average Americans, somebody like my mom, not a tax professional, ought to know about the tax system and ought to know about the IRS that they don't?

It's a great career for their kids and grandkids.

So I guess this is a plug to my mom. I made the right decision.

You got it. There you go, Stef.

This is the mom's episode. We all send this to our parents.

Yep.

It was mother's day recently. So there we go.

Yes.

Well, Fred, thanks so much for joining. It was really a pleasure. Jaclyn, you're doing amazing stuff. Thanks for guest hosting with us. We'll definitely have you back. We want to hear more about everything that you're doing.

Thank you so much. It was great to be here.

Thanks folks.

Thank you for joining us for today's episode of GILTI Conscience. 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.