The U.S. IRS has released two international practice units concerning advance pricing agreement for tangible goods transactions: Advance Pricing Agreement for Tangible Goods Transactions - Inbound; and Advance Pricing Agreement for Tangible Goods Transactions - Outbound. Each practice unit provides a detailed review, with a focus on: Understanding the APA process; Identifying Coverable Issues under the APA; Understanding the risk allocation between related parties; Pre-filing procedures; Rollback of the covered methods; Renewal of an APA; Compliance with APA terms and critical assumptions; The examiner's involvement in the APA process; Controlling the statue of limitations while an APA is under consideration;...