Seeking efficiencies in the new IRS APA and MAP programmes

November 01 2011

As part of its continuing efforts to improve international operations, the US Internal Revenue Service (IRS) recently announced the reorganisation of its advance pricing agreement (APA) and mutual agreement procedure (MAP) programmes into a combined advance pricing and mutual agreement (APMA) programme. Kerwin Chung and Todd Wolosoff of Deloitte explain what the reorganisation, and its potential impact on taxpayers seeking APAs, will mean.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login

Topics

more across site & shared bottom lb ros

More from across our site

Direct Tax

A taxing week: Nigel Farage could shake up UK tax policy

If the Reform leader becomes UK prime minister then he may follow the direction of the US in at least one significant way

Sam Sholli, August 01 2025

Direct Tax

This week in tax: Donald Trump approves additional 40% tariff on Brazil

Trump declared a new national emergency in issuing the order; in other news, Grant Thornton Germany is up for sale and the subject of interest from both its UK and US counterparts

Sam Sholli, August 01 2025

Transfer Pricing

Copenhagen (Nyhavn district) in a sunny summer day

Denmark v EET Group case sets important precedent, say experts

The judgment, which saw Denmark's Supreme Court rely on OECD TP guidance, sets aside more than 15 years of consistent administrative practice, experts have told ITR

Sam Sholli, July 31 2025

Direct Tax

Why Belgium’s exit tax rules could come under fire in the courts

Belgium’s new coalition government has gone ahead with a new exit tax regime that could land it in the courts

Ralph Cunningham, July 30 2025

Direct Tax

Proposed Brazil digital services tax would likely hit consumers, experts suggest

Brazil’s government has not officially framed the bill as a countermeasure amid trade tensions with the US, but the move is being considered as part of Brazil’s strategic response, one expert tells ITR

Sam Sholli, July 30 2025

Direct Tax

Income tax considerations for foreigners forming charitable foundations in India

Understanding India’s income tax landscape can help charities ensure compliance, optimise tax benefits, and enhance their impact, writes Raghav Bajaj of Khaitan & Co

Raghav Bajaj , July 29 2025

Indirect Tax

‘Brazil is not for amateurs’: Brazilian advisers praised for robust client service

Tax advisers in Brazil are rising above the country’s notoriously complex tax system to deliver high-quality advisory services, ITR’s exclusive in-house data reveals

Tom Baker, July 28 2025

Direct Tax

Holland & Knight tops the hiring charts again: ITR’s half-year Talent Tracker data

ITR’s data has highlighted the US firm’s ambition to become America’s ‘premier’ tax player via a concerted partner recruitment strategy

Tom Baker, July 25 2025

Direct Tax

This week in tax: A&M Tax launches Indonesia practice with ex-KPMG managing director

Jaap Zwaan’s arrival continues a recent streak of A&M Tax investing in the region; in other news, the US and Japan struck a deal that significantly lowered tariff rates

Tom Baker, July 25 2025

Transfer Pricing

Who gets taxed when no one’s there? AI, presence, and profit allocation

In a world where international tax concepts rely on human activity, Leonard Wagenaar poses existential questions about the future of such ideas when AI is ever-present

Leonard Wagenaar, July 24 2025