The United States (US) Internal Revenue Service’s (IRS) program to resolve transfer pricing disputes (Advance Pricing and Mutual Agreement Program (APMA)) is seeing "questionable treatment of COVID-related costs," according to an article in Tax Notes Today.1APMA director John Hughes said 5 March 2021, at the Federal Bar Association conference, that the APMA is seeing the following COVID-related issues: (i) taxpayers are classifying costs as nonoperating items to improve the controlled party's operating profitability for purposes of a comparable profits method or transactional net margin method analysis, which may result in a compensating adjustment; and (ii) taxpayers with an advance pricing...