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Internal Revenue Code (IRC) Organization for Economic Co-operation and Development Tax Liability

Miller Canfield

Trump Administration Opens the Door to Double-Tax-Rate Penalty on Foreign Companies and Individuals

Miller Canfield on

As part of its “America First Trade Policy,” the White House is exploring an arcane IRS provision that allows the United States to double the tax rates of foreign companies and individuals....more

Morgan Lewis

Key Considerations for the United States’ Notice Implementing OECD’s ‘Amount B’

Morgan Lewis on

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

Jones Day

U.S. Treasury and OECD Lay Groundwork for Selling Clean Energy Tax Credits

Jones Day on

In Short - The Situation: With the Inflation Reduction Act of 2022 (the "IRA"), Congress created new tax credits and expanded several others to encourage U.S. taxpayers to invest in clean energy and carbon reduction...more

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