According to recent comments from IRS officials, the IRS will begin the exchange of information on unilateral advance pricing agreements (APAs) by the end of the year as per BEPS Action 5. Although Action 5 sets out six categories of rulings to be exchanged, the IRS has so far only identified unilateral APAs as meeting the conditions for exchange. The six categories under Action 5 include: Rulings related to preferential regimes; Unilateral APAs and other transfer pricing rulings; Rulings that give unilateral downward adjustments; Permanent establishment rulings; Related party conduit rulings; and Other rulings subsequently agreed to give rise to...