In episode seven of "GILTI Conscience," hosts Nate Carden and David Farhat talk with Keystone Strategy's Bram Isgur about the issue underlying most major transfer pricing cases: whether to look forward to see what pricing should be for events that have not yet happened or to wait and look back at what has already occurred. As Bram acknowledges, there is no perfect solution: Transfer pricing theories are ex ante, transfer pricing audits are ex post, and OECD guidelines and U.S. transfer pricing rules are a mix of the two.

Response to the Russian invasion of Ukraine has been swift and coordinated. The U.S., U.K. and EU, among other allied nations, have imposed a series of sanctions and export controls on key elements of the Russian economy.