David Weisbach, a former Treasury Department official who helped write the regulations governing the tax-code provision that Bristol Myers is accused of violating, agreed. PwC and White & Case “are giving you 138 pages of legalese that doesn’t address the core issue in the transaction,” he said. “But you can show the I.R.S. you got this big fat opinion letter, so it must be fancy and good.”

The current status of the tax dispute is not clear. Similar disputes have spent years winding through the I.R.S.’s appeals process before leading to settlements. Companies often agree to pay a small fraction of what the I.R.S. claims was owed.

“There is a real chance that a matter like this could be settled for as little as 30 percent” of the amount in dispute, said Bryan Skarlatos, a tax lawyer at Kostelanetz & Fink.

In that case, the allegedly abusive tax shelter would have saved Bristol Myers nearly $1 billion.


‘There Is a Bigger Role’: A C.E.O. Pushes Diversity

I don’t blindly accept that the pipeline is the problem. We had to think differently. We had to behave differently. So what we’ve tried to show with our transparency is the deliberate steps you can take to get better.

What have the conversations been like with white men?

When we looked at the teams inside PwC that were servicing our top clients six years ago, they were done by white men. We made the decision that we were going to change that. So we invested more in our pipeline. We did more around sponsorship. We worked with our clients. And we’ve made massive progress there. But as we did that, many of our white men were like, “I get it intellectually. But God, I’ve been working for 20 years to be that guy in that job. And I feel cheated.” I’ve had 50 steak dinners in the last four years with incredibly talented white men who say to me, “Tim, I get it. I see what we’re doing. Our clients demand it. It’s the right thing to do. I’m all in. But what about me?”

So we’ve tried to redefine success. You may not be the lead partner, but how about helping that person get the role? What would you rather be remembered for? What do you want to be inspired by? And the reason why growth is so important is that it’s not a zero-sum game. When you’re growing, you’re creating more opportunities. It becomes less about these 20 clients. Now we’ve grown, and there’s 30 clients to share the wealth.

Are there people who just feel like they got cheated? Yes, there are. And what I say to those people is, “I’m asking you to respect what we are trying to do. I’m asking you to respect our colleagues. I’m asking you to have compassion. And if you don’t agree, that’s OK. You don’t have to agree with me. But I do need you to live our values.”

How did the pandemic unfold at PwC?

Our people are all over the world in different countries. When the pandemic hit, as borders shut down, as transportation shut down, the first thing it was all about was just getting people safe, getting them home.

Then, in the later part of March, think about the equity markets. Think about the uncertainty. People were worried about their health and worried about their financial security. My leadership team, my board and I, we talked about the fact that we’re not a health-care provider. We’re not a health-care company. So we talked about economic certainty for our people, and we said we would use layoffs only as a last resort. We did that having no idea where our business was going to go.

Our business took a dip and, and we sat down every week and looked at the numbers, asking ourselves along, “Can we do this? Have we made the right decision?” And we held on. Outside of performance-based layoffs, which is a traditional part of business, we got through it.


E.U. Pushes Companies to Close Gender Pay Gap

BRUSSELS — Pushing member states to address salary disparities between men and women, the European Union revealed details on Thursday of a proposed law that would require companies to divulge gender pay gaps and give job candidates access to salary information in employment interviews. It also would provide women with better tools to fight for equal pay.

The move comes as female workers across the world have been disproportionately affected by the economic repercussions of the coronavirus crisis, and it could lead to sanctions on companies that do not comply.

The proposed law would also empower women to verify if they are being fairly compensated in comparison with male colleagues. The European Commission, the bloc’s executive arm, wants to provide workers with the ability to seek proper compensation in case of discrimination.

Under the proposed law, those who believe they are victims could take action through independent monitors of compliance with the equal-pay requirement. They could also press gender-based pay grievances through workers’ representatives, either as individuals or in groups.

European Institute for Gender Equality, a research group, female managers earn a quarter less than male ones.

Despite several efforts to enforce equal pay in practice, for more than 60 years it seemed out of reach for women across the bloc, which presents itself as the beacon of human rights and equality. So far, only 10 European countries, including Austria, Germany, Italy, and Sweden, have introduced national legislation on pay transparency.

The proposed E.U.-wide law requires approval by member countries and the European Parliament. There are concerns that it might be blocked by national governments, as happened with the European Commission’s proposal to introduce gender quotas on management boards. Wary of these potential obstacles, Vera Jourova, the bloc’s top official for values and transparency, called the proposal on pay “pure pragmatism and good economic calculations,” underlining that gender equality at work benefited businesses.

2020 Women in Work Index, compiled annually across 33 developed countries by PricewaterhouseCoopers, a consultancy, economic damage from the pandemic, as well as repercussions from government policies, is disproportionately affecting women. This has reversed the steady trend of gains for women in employment and has led to what the consultancy calls a “shecession.”

Women’s rights groups welcomed the commission’s initiative. “Information is power: pay transparency would enable employees to know the value of their work and negotiate salaries accordingly,” said Carlien Scheele, director of the European Institute for Gender Equality. “This would help tackle discrimination in the workplace, which can only be a boon for gender equality.”

Employers, aware of the proposal’s possible legal and economic repercussions, were careful in their assessment, blaming what they described as deep underlying reasons for gender inequalities.

“Reasonable requirements on pay transparency can be part of the answer,” said Markus J. Beyrer, head of BusinessEurope, a lobbying group. “However, the key to improve gender equality is to address the root causes of inequalities, especially gender stereotypes, labor market segregation and insufficient provision of child care.”

Mr. Beyrer said the commission must respect “national social partners’ competences” and should not “complicate human resources management with excessive administrative burdens and open the way to undue litigation.”

According to Ms. Jourova, “binding rules” are required, not just reliance on the social responsibility undertaken by companies. “We see that it doesn’t lead anywhere,” she said.