The US Internal Revenue Service (IRS) has recently published on its web page that the IRS’s Advance Pricing and Mutual Agreement Program (APMA) is soliciting comments on a proposed revision to the template for advance pricing agreements (APAs). The revision reflects a substantial change from prior templates.
The proposed template is more comprehensive, and as a result is longer than previously published templates. To help taxpayers become comfortable with the template, it is accompanied by detailed instructions, and a filled-in example supplemented by explanatory comments. The template will also serve as a roadmap for taxpayers of possible issues and approaches in drafting an APA. Comments should be directed to lbi.ttpo.apma.feedback@irs.gov by October 31, 2017, with the subject line “comments”.
