EYUS IRS representatives say MAP and APMA cases are more difficult because of high adjustments, express concern about unilateral relief
|Tax Alerts, Transfer Pricing|United States
The large adjustments involved in mutual agreement procedures (MAP) cases is making those cases hard to handle through the dispute resolution process, a director at the IRS Large Business and International Division said.1
In a separate webcast, the director of the Advance Pricing and Mutual Agreement Program (APMA) “expressed concern that agreeing to unilateral relief offered by a [US] treaty partn…
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