Seeking efficiencies in the new IRS APA and MAP programmes

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Cookies Settings

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

FeatureITR MagazineNovember 2011
more across site & shared bottom lb ros

More from across our site

Direct Tax
Africa
A taxing week: The OECD must take developing countries seriously
Given the US/G7 pillar two deal, the OECD is in danger of being replaced by the UN as the leading global tax reform forum
Sam Sholli, September 12 2025
Direct Tax
Irvine, CA, USA - May 6, 2022: Grant Thornton logo is seen at the company's office in Irvine, California. Grant Thornton LLP is a global independent accounting and advisory organization.
This week in tax: PE house Cinven invests in Grant Thornton Germany
Cinven’s latest investment follows its acquisition of a stake in Grant Thornton UK in December; in other news, a barrister listed by HMRC as a tax avoidance promoter has alleged harassment
Tom Baker, September 12 2025
Direct Tax
OECD
Corporate income tax rate reductions slowing down: OECD report
CIT base narrowing measures remain more prevalent than increased CIT rates, the report also highlighted
Sam Sholli, September 11 2025
Direct Tax
lbg logo.png
Legal Benchmarking Group acquires The Lawyer
ITR's parent company, LBG, will acquire The Lawyer, a leading news, intelligence and data-driven insight provider for the legal industry, from Centaur Media
Ed Conlon, September 11 2025
Transfer Pricing
UK and Netherlands
Multilateral APAs in the UK and Netherlands: a history
KPMG UK’s Graeme Webster and KPMG Meijburg & Co’s Eduard Sporken outline the 20-year evolution of MAPAs, with DEMPE analyses becoming more prevalent and MAPA requirements growing stricter
Graeme Webster, September 11 2025
Direct Tax
Telecommunication tower Antenna at sunset sky.
Input tax credit eligibility for telecom towers: Indian case law analysis
Rishi Joshi, of the Institute of Chartered Accountants of India, warns of potential judicial overreach as assets are recharacterised to bypass a legislative exclusion
Rishi Joshi, September 10 2025
Transfer Pricing
Pia Honkala and Prasad Pardiwala.png
TP costs rocket for MNEs, report reveals
Only 2% of in-house survey respondents said they were ‘heavy’ users of AI for TP, Aibidia’s report also found
Tom Baker, September 09 2025
Direct Tax
Oslo, Norway - 24 September 2022: PricewaterhouseCoopers or PWC
Ex-PwC Australia CEO Thomas Seymour deregistered over tax scandal role
There was a ‘deeply embedded culture within PwC that routinely disregarded formal confidentiality obligations,’ the chairman of Australia’s Tax Practitioners Board said
Sam Sholli, September 09 2025
Direct Tax
Baker McKenzie
Baker McKenzie hires senior IRS official in US
Jennifer Best was most recently the acting commissioner of the IRS’s large business and international division
Sam Sholli, September 08 2025
Direct Tax
ArunaKalyanam.jpg
Bipartisan US opposition to DST ‘revenue pursuits’: EY leader
Section 899’s exclusion from the One Big Beautiful Bill does not mean it has been nipped in the bud, Aruna Kalyanam also tells ITR
Sam Sholli, September 08 2025
Gift this article