Transfer pricing enforcement is undergoing significant changes in both the United States and Ireland, with the two jurisdictions actively moving in different directions. While the United States is experiencing internal...more
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
The Organization for Economic Cooperation and Development recently proposed that consumer-facing businesses that make nonroutine profits would be taxed in market jurisdictions where consumers are located, regardless of where...more