IRS Planning Changes to Advance Pricing Agreement Process

The IRS is working on a new process for companies applying for advance pricing agreements, to help give them a clearer idea of how the government will view their application.

“Once finalized, we expect that there will be a mechanism for taxpayers to come in and obtain APMA’s preliminary view on whether the APA workstream is well-suited to successfully achieve the certainty for the proposed covered transactions, before they undertake to draft and submit a formal APA request,” said Jennifer Best, acting deputy commissioner of the Large Business and International Division at the IRS. She was speaking ...