The U.S. IRS Large Business and International (LB&I) division has issued Memorandum LB&I-04-0425-0005 of 22 April 2025 on the review and acceptance of advance pricing agreement (APA) submissions. This is a reissue of interim guidance memorandum LB&I-04-0423-0006 of 25 April 2023. The guidance provides instructions to LB&I employees requiring consideration of specified criteria for the review of each APA prefiling memorandum and each APA request, including requests for APA renewals, before determining whether an APA request will be accepted into the advance pricing and mutual agreement (APMA) program. The memorandum applies to APA prefiling memoranda and APA requests, including renewal...