News & Analysis as of

Advanced Pricing Agreements

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

Eversheds Sutherland (US) LLP

Louisiana Department of Revenue implements managed audit program to address transfer pricing issues

The Louisiana Department of Revenue (the Department) issued Revenue Information Bulletin No. 21-029 (the Bulletin), inviting corporate income taxpayers to resolve intercompany transfer pricing issues via the Louisiana...more

Morgan Lewis

Beware States Offering Unilateral Advance Pricing Agreements for Transfer Pricing

Morgan Lewis on

As state revenue agencies train their auditors in traditional IRC §482 transfer-pricing methodologies or outsource transfer-pricing audits to third-party specialists, a recent initiative by the Indiana Department of Revenue...more

Orrick, Herrington & Sutcliffe LLP

New Panel, Same Result – Ninth Circuit Upholds Controversial Cost-Sharing Regulations in Altera Case

The unfolding Altera Corporation & Subsidiaries v. Commissioner (Altera) saga bore witness to another taxpayer-unfriendly development on June 7, when the Ninth Circuit chose in a 2-1 vote to uphold certain Treasury...more

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