Gregory Hartker

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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

IRS and Treasury Release Credit Transfer Guidance Aiming to Jump Start Market for Ira's Clean Tech Industry Tax Credit Sales

On June 14, 2023, the Internal Revenue Service (IRS) and US Department of the Treasury (Treasury) released temporary regulations (Temporary Regulations) and proposed regulations (Proposed Regulations; collectively with the...more

6/26/2023 / Energy Projects , Energy Sector , Inflation Reduction Act (IRA) , Investment Tax Credits , IRS , Production Tax Credit , Tax Credits , U.S. Treasury

The GILTI Rules – A Comprehensive Q&A on the New Proposed Regulations

The US Department of the Treasury and the Internal Revenue Service provided guidance on the Global Intangible Low Taxed Income rules, answering some, but by no means all, of the questions raised by taxpayers and practitioners...more

9/21/2018 / GILTI tax , IRS , Tax Cuts and Jobs Act , Tax Reform , U.S. Treasury

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