The U.S. IRS Large Business and International (LB&I) division has issued Memorandum LB&I-04-0425-0005 of 22 April 2025 on the review and acceptance of advance pricing agreement (APA) submissions. This is a reissue of interim guidance memorandum LB&I-04-0423-0006 of 25 April 2023. The guidance 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 ren…