As promised before the end of 2024, the I.R.S. has outlined its approach to the codification of Amount B, a component of the O.E.C.D. Pillar One approach to controlled distribution transactions of tangible property. Notice 2025-04 allows taxpayers to elect to use the streamlined, simplified approach (“S.S.A.”) for corporate tax years beginning on or after January 1, 2025.  If a valid election is made, the I.R.S. will consider the S.S.A. to be the best method under the Treas. Reg. §1.482-1(c). While touted as a method that brings simplicity to transfer pricing, in practice simplicity is achieved at the price of certain important concepts fundamental to the arm’s length standard codified in tax law. Michael Peggs does yeoman’s work in taking the reader through the steps to be followed, the conditions to be applied, and the variable values that pop out of the S.S.A. machine. To readers who have given transfer pricing advice over the years, Amount B may seems to be based on concepts of the command economy of bygone days rather than market transactions.