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US IRS interim guidance on review and acceptance of Advance Pricing Agreement submissions fundamentally changes early stages of the process

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United States

  • The interim guidance, which is effective immediately, is intended to allow the US Internal Revenue Service (IRS) to determine a taxpayer's suitability for an Advance Pricing Agreement (APA), or, alternatively, another dispute resolution process.
  • While stating that the guidance is not meant to decrease the number of APA requests accepted, the IRS also says that it will consider whether a taxpayer wi…

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