Executive summaryThe United States (US) Internal Revenue Service (IRS) Advance Pricing and Mutual Agreement (APMA) Program issued the 23rd annual Advance Pricing Agreement (APA) report (the Report) on 22 March 2022, in Announcement 2022-7. The Report discusses APMA, including its activities and structure for calendar year 2021, and gives useful insights into the operation of the APA Program.The number of APA filings increased in 2021, with taxpayers filing 145 APA requests (up from 121 in 2020). The total number of APAs concluded, however, decreased from 127 to 124 and the median of time to finalize an APA increased from 32.7 months...