The U.S. IRS has issued Notice 2025-04, announcing that the Department of the Treasury and the IRS intend to issue proposed regulations that, for purposes of applying section 482, provide a new simplified and streamlined approach (SSA) for pricing certain controlled transactions involving baseline marketing and distribution activities. The SSA is based on the OECD Report on Pillar 1 Amount B that was issued in February 2024. The Notice also provides guidance concerning the application of the SSA to in-scope transactions undertaken by parties subject to U.S. tax with respect to transactions before the issuance of the proposed regulations.  Taxpayers may...