The U.S. IRS recently released Announcement 2025-13, Announcement and Report Concerning Advance Pricing Agreements. The report describes the experience, structure, and activities of the Advance Pricing and Mutual Agreement Program during the calendar year 2024. As compared to 2023, 2024 saw a slight increase in APA applications filed from 167 to 169, along with a decrease in APAs executed from 156 to 142. 2024 also saw a decrease in the completion time for an APA from 42 months in 2023 to 33.5 months in 2024 for new and renewal APAs. By a large margin, the two most common countries involved...