IRS Boosting Tax Dispute Talks With Difficult Jurisdictions

May 11, 2026, 10:29 PM UTC

The IRS is increasing informal talks with other tax authorities to speed up progress on bilateral advance pricing agreements, and is urging taxpayers to communicate more actively to speed tax dispute negotiations, an agency official said Monday.

The agency is also updating guidance that details procedures governing APAs, John Wall told an event hosted by Alston & Bird.

Work on Revenue Procedure 2015-41 is “very, very, very far along,” he said, with the Treasury Department and counsel’s office meeting regularly on it. He didn’t give a timeline for completion.

Wall, director of the agency’s Advance Pricing and Mutual Agreement Program, ...

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