Thomas Linguanti

Thomas Linguanti

Morgan Lewis

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Evolving Transfer Pricing Controversy: Divergent Paths in the United States and Ireland

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

7/31/2025  /  Audits , Enforcement , International Tax Issues , Ireland , IRS , OECD , Tax Avoidance , Tax Planning , Transfer Pricing

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
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