Executive summaryThe United States (US) Internal Revenue Service (IRS) Advance Pricing and Mutual Agreement (APMA) Program issued the 21st annual Advance Pricing Agreement (APA) report (the Report) on 25 March 2020, in Announcement 2020-2. The Report provides a discussion of the APMA Program, including its activities and structure for calendar year 2019, and gives useful insights into its operation.The number of APA filings decreased, with taxpayers filing 121 APA requests in 2019 compared to 203 in 2018. This decrease is not surprising given that APMA substantially increased the user fees charged to companies applying for an APA starting after 2018. The...