Our International Tax Group unpacks recent IRS guidance and public comments that reveal how the agency is changing its advance pricing agreement (APA) procedures. The Large Business and International Division released a...more
Last year’s historic demand with a smaller staff compounded 2021’s challenges for the Advance Pricing and Mutual Agreement Program (APMA). Our International Tax Group delves into this year’s annual report to evaluate trends...more
Our International Tax Group reviews a pair of tax decisions clarifying the IRS’s ability to cancel advance pricing agreements and how the arm’s-length standard applies to high-value intercompany licensing transactions. ...more
Despite adding personnel and making a concerted effort to speed up the advance pricing agreement process, the Advance Pricing and Mutual Agreement Program (APMA) faces challenges with the mounting demand. Our International...more
Our International Tax Group analyzes the report on the IRS’s Advance Pricing and Mutual Agreement Program and identifies important insights and trends for advance pricing agreements....more