The large adjustments involved in mutual agreement procedures (MAP) cases is making those cases hard to handle through the dispute resolution process, a director at the IRS Large Business and International Division said.1In a separate webcast, the director of the Advance Pricing and Mutual Agreement Program (APMA) “expressed concern that agreeing to unilateral relief offered by a [US] treaty partner jurisdiction may become an obstacle to receiving full relief from double taxation.”2APMA is the program within the IRS charged with trying to eliminate double taxation typically caused by transfer pricing adjustments on intercompany cross-border transactions made by the tax authority...