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Advance Pricing Agreements APMA

Alston & Bird

What to Make of the IRS’s New “Gatekeeping” Guidance for Advance Pricing Agreements

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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

Alston & Bird

Searching for “Green Shoots” After a Difficult Year for IRS’s Advance Pricing and Mutual Agreement Program

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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

Alston & Bird

IRS APMA’s Results May Suggest COVID-19 Immunity

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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

Skadden, Arps, Slate, Meagher & Flom LLP

"IRS Implements Final Changes to Advance Pricing Agreement Process"

On August 12, 2015, the IRS issued Rev. Proc. 2015-41, which sets out the procedures for pursuing advance pricing agreements (APAs). The new revenue procedure replaces Rev. Proc. 2006-9 and finalizes revenue procedures...more

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