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Internal Revenue Service › Transfer Pricing › New Guidance

The United States Internal Revenue Service is a bureau of the United States Department of the Treasury. The IRS is charged with collecting revenue and enforcing the Internal Revenue Code.  
Alston & Bird

IRS’s Advance Pricing and Mutual Agreement Program Rebounds in 2023: What Is APMA’s Long Game?

Alston & Bird on

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

Morrison & Foerster LLP

MoFo Tax Talk - Volume 8, No. 3

Morrison & Foerster LLP on

Final and Temporary Dividend Equivalent Regulations Issued – Some Good, Some Bad, And Some Ugly: On September 17, 2015, the Internal Revenue Service (“IRS”) released final and temporary regulations under Section 871(m),...more

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