The OECD’s “Amount B” and IRS Notice 2025-04: Will Treasury’s Proposed Regulations Solve as Many “Problems” As They May Create?

This webinar will delve into the recent IRS Notice 2025-04 and US Department of the Treasury’s intention to issue proposed regulations ostensibly implementing “Amount B” under the OECD’s Pillar One approach to marketing and distribution. During this session, our cross-disciplinary tax team will analyze the new notice and discuss its potential effect on multinational tax planning as well as on current and future tax controversies – and how to prepare for each.