The U.S. IRS recently released Announcement 2024-16, Announcement and Report Concerning Advance Pricing Agreements. The report describes the experience, structure, and activities of the Advance Pricing and Mutual Agreement Program during the calendar year 2023. As compared to 2022, 2023 saw a decrease in APA applications filed from 183 to 167, but with a marked increase in APAs executed from 7…