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US IRS maintaining its policy on “telescoping” in APA and MAP cases while trying to alleviate administrative burden, official says

14 October 2021

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Tax Alerts, National/Federal Taxation, T...

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United States

John Hughes, Director of the Internal Revenue Service’s (IRS) Advance Pricing and Mutual Agreement Program (APMA), said in a 7 October 2021, webinar that the IRS is maintaining its stance on telescoping but studying ways that it can alleviate the taxpayers' administrative burden, according to an article in Law 360.1In October 2020, APMA updated the parameters that it follows in mutual agreement procedure (MAP) and advance pricing agreement (APA) cases, which significantly restricted the use of "telescoping" of results in MAPs and APAs (see EY Global Tax Alert, US IRS announces plans to limit the use of “telescoping” in APA and MAP...