The Resource Advance pricing agreements in the United States : in a state of flux?

Advance pricing agreements in the United States : in a state of flux?

Label
Advance pricing agreements in the United States : in a state of flux?
Title
Advance pricing agreements in the United States : in a state of flux?
Creator
Subject
Language
eng
Summary
On 26 February 2012, the U.S. IRS introduced a significant organizational change to its advance pricing agreement (APA) program, merging this program with the area of the office of the U.S. competent authority dedicated to resolving transfer pricing disputes under the mutual agreement procedures (MAP) of U.S. income tax treaties. The consolidation of these two areas into a single program, the advance pricing mutual agreement office, within the Large Business and International Division, marked the beginning of a new direction regarding the resolution of transfer pricing disputes within the IRS. This article examines the innovative processes and proposed reforms that emerged from the consolidation, along with the internal and external challenges accompanying this paradigm shift in the IRS's approach to dealing with APAs. It evaluates the effects of this change and the impact of the new processes introduced on agreement completions. It also examines the IRS's proposed new revenue procedure for such agreements, giving consideration to the anticipated consequences of the major changes envisaged and taking into account the comments provided by key stakeholders in the process
Citation source
In: Tax notes international. - Falls Church. - Vol. 78 (2015),
http://library.link/vocab/creatorName
Markham, M
Geographic coverage
North America
Language note
English
http://library.link/vocab/subjectName
  • APA
  • MAP
  • transfer pricing
Label
Advance pricing agreements in the United States : in a state of flux?
Instantiates
Publication
Label
Advance pricing agreements in the United States : in a state of flux?
Publication

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