The U.S. IRS has released two international practice units concerning advance pricing agreement for tangible goods transactions: Advance Pricing Agreement for Tangible Goods Transactions - Inbound; and Advance Pricing Agreement for Tangible Goods Transactions - Outbound. Each practice unit provides a detailed review, with a focus on:
- Understanding the APA process;
- Identifying Coverable Issues under the APA;
- Understanding the risk allocation between related parties;
- Pre-filing procedures;
- R…