On May 11, 2018, the IRS’s Advance Pricing and Mutual Agreement Program (APMA) issued a new template that taxpayers must use when requesting an advance pricing agreement (APA) under Rev. Proc. 2015-41, 2015-35 I.R.B. 263 (Rev. Proc. 2015-41). Taxpayers with pending APA requests should contact their assigned APMA team leader(s) about whether to use this template in their cases.
The current version of the template continues to use an options-based format. APMA believes this format will facilitate the submission and review of APA requests and the drafting of APAs. The new APA template and related instructions reflect changes that were made in response to comments received about draft versions issued by the IRS in September 2017. The new APA template allows some editing by taxpayers “in appropriate cases.”
