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: Ryan’s day at the zoo was more than animalistic self-promotion

CSR initiatives can sometimes venture into virtue signalling, but Ryan’s tax literacy event for schoolchildren was a genuine and necessary endeavour

Tom Baker, May 01 2026

Direct Tax

This week in tax: Grant Thornton extends consolidation drive to Australia

Grant Thornton advanced plans to integrate its Australian firm into its US arm, as tax developments spanned law firm hires, aviation levies and digital services taxes

Tom Baker, May 01 2026

Transfer Pricing

TP audits are moving upstream, but can African authorities keep pace?

A new focus on early intervention and increased AI use is transforming how tax authorities are approaching TP audits, though capacity-constrained jurisdictions risk falling behind

Akashni Ashok Latchanna, April 30 2026

Direct Tax

French tax authority leads way in AI adoption

The French administration has used AI to detect undeclared swimming pools and verandas but always includes a human in the loop, the AI in Tax Forum heard

Ed Conlon, April 29 2026

Direct Tax

HMRC invites taxpayers to stress-test pillar two filings in ‘private beta’

The UK tax authority’s deputy director of large business also reassured taxpayers that HMRC will not ‘nitpick’ returns

Tom Baker, April 28 2026

Direct Tax

David Beringer, Sucafina, ITR P2 Forum 2026.JPG

Pillar two a ‘box-ticking’ exercise, admits MNE tax head

Sucafina’s tax chief was speaking at the ITR Pillar 2 Forum in London alongside experts from HMRC and other organisations

Ed Conlon, April 28 2026

Direct Tax

Tiger Global ruling in India: scope, limits and risks

India’s Supreme Court rattled cross‑border structuring with its Tiger Global ruling. Subsequent rule changes narrowed the impact, but significant risks around GAAR, substance and treaty access persist

Ravish Bhatt, April 28 2026

Direct Tax