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Key Considerations for the United States’ Notice Implementing OECD’s ‘Amount B’

The Internal Revenue Service (IRS) has released Notice 2025-04 announcing the IRS and US Department of the Treasury’s intention to issue proposed regulations implementing “Amount B,” the OECD’s new method (also known as the...more

1/17/2025  /  Corporate Taxes , Income Taxes , Internal Revenue Code (IRC) , IRS , OECD , Tax Liability , Tax Planning , U.S. Treasury

Tax Reform Legislation Reverses Grecian Magnesite Mining, Adds New Withholding Tax

New provisions will have a significant impact on secondary sales of fund interests and partnership M&A transactions. On December 22, 2017, US President Donald Trump signed into law the sweeping tax reform bill H.R. 1 (the...more

12/28/2017  /  Acquisitions , Internal Revenue Code (IRC) , Mergers , Tax Reform , Withholding Tax
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