APMA set a record for executed advance pricing agreements (APAs), but high processing times and a hefty pending APA inventory continued to challenge APMA in 2023. Our Federal & International Tax Group evaluates trends gleaned...more
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 analyzes the report on the IRS’s Advance Pricing and Mutual Agreement Program and identifies important insights and trends for advance pricing agreements....more