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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

IRS’s Implicit Parental Support Guidance ‘Formalizes’ Past Litigation Position

The Internal Revenue Service (IRS) recently issued a nonbinding Generic Legal Advice Memorandum (GLAM) that provides advice on Internal Revenue Code Section 482 and so-called implicit parental support. Consistent with prior...more

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