The U.S. IRS has issued a release announcing that U.S. taxpayers with maquiladora operations in Mexico will not be exposed to double taxation if they enter into a unilateral advance pricing agreement (APA) with the Large Taxpayer Division of Mexico’s Servicio de Administración Tributaria (SAT) under terms discussed in advance between the U.S. and Mexican competent authorities. The terms are included in an update and extension of the 1999 agreement between the competent authorities on transfer pricing and other aspects of the tax treatment of maquiladoras of U.S. multinational enterprises. For qualifying taxpayers with pending unilateral APA requests, the SAT...