The Internal Revenue Service (IRS) Large Business and International (LB&I) division released a memorandum providing guidance to employees of the Treaty and Transfer Pricing Operations (TTPO) practice area in the Large Business and International Division (LB&I) with respect to requests from taxpayers for an APA with the IRS on 25 April 2023.
The guidance applies to both APA prefiling memoranda and APA submission requests, including renewals. The guidance applies to TTPO personnel and includes the process, the criteria to be considered, and the personnel to be included in determining whether a proposed APA request likely will be most successfully treated in the APA process or in another TTPO workstream. This guidance will be incorporated into IRM 4.60.3 by a date not to exceed two years from its release.
