Nicole Welch, IRS's Large Business and International (LB&I) Division Director of Treaty and Transfer Pricing Operations, said the United States encourages jurisdictions to pursue mandatory binding arbitration to strengthen their mutual agreement procedure (MAP) programs.1Speaking on March 7, 2024, at a Global International Fiscal Association program in Washington DC, Welch said mandatory binding arbitration is the US tax treaty policy.2 Mandatory binding arbitration is included in the 2016 US model tax treaty and the bilateral US income tax treaties with Belgium, Canada, Croatia,3 France, Germany, Japan, Spain and Switzerland.4 MAP disputes can be brought to an arbitration panel if the...