Proposed Template for Advance Pricing Agreements

The Advance Pricing and Mutual Agreement Program (“APMA”) of the Internal Revenue Service (“IRS”) has provided for public discussion, a draft updated template for use in drafting advance pricing agreements (“APAs”).  It is designed to “systemize how taxpayers propose terms for their APAs and standardize language used in executed APAs” as well as “improve efficiency [...]

Proposed Template for Advance Pricing Agreements 2018-02-20T18:13:42+00:00