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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

Waiting for Guidance from Treasury on Tax Reform or Relying on IRS Rulings? Read This First

A recent policy statement from the US Department of Treasury provides important information for taxpayers navigating US tax reform and alters the existing tax regulatory landscape in a few meaningful ways. Taxpayers should be...more

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