The United States (US) Internal Revenue Service (IRS) has announced that it has reached an agreement with the Mexican Tax Authority (SAT) to renew the competent authority agreement arrangement known as the Qualified Maquiladora Approach Agreement (QMA). Under the QMA, a US taxpayer can avoid double taxation on its maquiladora contract manufacturing and assembly functions by entering a unilateral advance pricing agreement (APA) with SAT’s large taxpayer division under terms agreed in advance by the US and Mexican competent authorities.The US and Mexican competent authorities last negotiated a QMA agreement in 2016. The 2016 QMA updated and expanded a 1999...