The U.S. IRS Large Business and International (LB&I) division has issued a memorandum containing interim guidance on the review and acceptance of advance pricing agreement (APA) submissions. The memorandum, dated 25 April 2023, provides instructions to LB&I employees requiring consideration of specified criteria for the review of each APA prefiling memorandum and each APA request, including requests for APA renewals, before determining whether an APA request will be accepted into the…