The IRS’s Advance Pricing and Mutual Agreement Program (APMA) is seeking comment on a proposed revision to the template for advance pricing agreements (APAs). The revision is intended to:
- Facilitate quicker and more accurate drafting of APAs;
- Provide more guidance to taxpayers in preparing the proposed draft APA that is required as part of an APA Request;
- Facilitate APMA’s review of draft APAs; and
- Facilitate the Mutual Agreement process for bilateral and multilateral APAs.
To achieve thes…