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IRS reissues interim guidance on Advance Pricing Agreement submissions

|Tax Alerts, Transfer Pricing, National/F ...|United States
United States

  • The interim guidance allows the IRS to determine a taxpayer's suitability for an Advance Pricing Agreement (APA), or, alternatively, another dispute resolution process.
  • The interim guidance has been reissued because the original guidance expired on April 25, 2025; the updated guidance expires on October 22, 2025.
  • The new procedures do not seem to have reduced the number of APAs accepted into the APA…

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