Tax Pros Wonder About Outlook as IRS Pricing Agreements Slow

April 3, 2026, 8:45 AM UTC

The diminished number of advance pricing agreements the IRS completed last year has tax practitioners wondering what the agency will do to get more APAs done with fewer resources.

The agency’s Advance Pricing and Mutual Agreement Program reported this week that it signed just 110 APAs last year, down from 142 the year before, while new applications ticked up to 178.

Among the culprits were personnel cuts and departures at APMA, which brought staffing levels down to 108, from 126 the year before.

“Taxpayer demand for APAs remains strong, as reflected in the continued volume of filings, but the more ...

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