Changes to IRS APA Program Receive Mix of Praise, Concern

Published on August 11, 2011 – Bloomberg BNA

The Internal Revenue Service’s plan to relocate its Advance Pricing Agreement Program to an office in the Large Business and International Division has received a mix of optimism and concern among private practitioners.

Under the planned relocation, efficiency and increased accessibility are expected to be key advantages, while some transitional details concern practitioners as Service employees undergo training for new job responsibilities.

As announced July 27, the program will be combined with the IRS’s competent authority function to form the Advance Pricing and Mutual Agreement (APMA) program and will be under the IRS transfer pricing director. As part of the restructuring, the competent authority and international coordination functions also will be adjusted to come under a new position, the Assistant Deputy Commissioner (International) (20 Transfer Pricing Report 283, 7/28/11).

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