The interim guidance, which is effective immediately, is intended to allow the US Internal Revenue Service (IRS) to determine a taxpayer's suitability for an Advance Pricing Agreement (APA), or, alternatively, another dispute resolution process.While stating that the guidance is not meant to decrease the number of APA requests accepted, the IRS also says that it will consider whether a taxpayer will be most successful in the APA program or an alternative workstream (e.g., International Compliance Assurance Program (ICAP), a joint audit or a domestic audit).In a 25 April 2023 Memorandum for Treaty and Transfer Pricing Operations Employees (memo), the US...