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Advance Pricing Agreements Transfer Pricing Internal Revenue Service

McDermott Will & Emery

IRS Roundup March 15 – March 28, 2025

Check out our summary of significant Internal Revenue Service (IRS) guidance and relevant tax matters for March 15, 2025 – March 28, 2025. IRS GUIDANCE - March 17, 2025: The IRS issued Revenue Ruling 2025-8, providing...more

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

Skadden, Arps, Slate, Meagher & Flom LLP

IRS Issues Interim Guidance to Staff on Reviewing and Accepting Advance Pricing Agreement Submissions

The Internal Revenue Service (IRS) recently released instructions for employees that may have the effect of deterring some companies from submitting advance pricing agreement (APA) requests. That, in turn, could introduce...more

Holland & Knight LLP

The New IRS Selectivity Criteria for Advance Price Agreements and Renewals

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The IRS has announced new rules relating to the acceptance of Advance Pricing Agreement (APA) and renewal requests. On April 25, 2023, the IRS published interim guidance (the Interim Guidance), effective as of that date, that...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

Eversheds Sutherland (US) LLP

IRS issues annual Advance Pricing Agreement Report for 2022

On March 27, 2023, the Internal Revenue Service (IRS) issued its Announcement and Report Concerning Advance Pricing Agreements (APA Report) for 2022, which presents the key APA results of the IRS’s Advance Pricing and Mutual...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

Alston & Bird

Big Tax Court Win for Eaton in Canceled APA Case

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In a significant taxpayer victory, the Tax Court, in a memorandum decision, has ruled in Eaton Corp. & Subsidiaries v. Commissioner that the IRS’s decision to cancel Eaton Corporation’s two advance pricing agreements (APAs)...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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