The United States (US) Internal Revenue Service’s (IRS) Advance Pricing and Mutual Agreement program (APMA) has announced that it is updating the parameters that it follows in mutual agreement procedure (MAP) and advance pricing agreement (APA) cases. The updates are expected to significantly restrict the use of “telescoping” of results in MAPs and APAs.TelescopingTelescoping refers to reflecting an income tax adjustment in a year different from the year to which the adjustment relates. Taxpayers sometimes request this departure from the notion of annual accounting in a MAP or APA to relieve the administrative burden of filing multiple amended federal and...