U.S. IRS Consults on New APA Template
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…