Advance pricing agreements: policy and practice
Article Abstract:
The advance pricing agreement (APA) program was established by the IRS in 1991 to provide multinational businesses with greater certainty regarding transfer pricing and to increase compliance with complex regulations under IRC section 482. Under an APA, the taxpayer and the IRS agree to apply certain transfer pricing methods to intercompany transactions to ensure that all such transfers are consistent with arms-length valuations. Revenue Procedure 91-22 details the application process, negotiation, competent authority and administration of APAs.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1995
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The new U.S. model tax treaty
Article Abstract:
The US Model Income Tax Convention and Technical Explanation, released by the Treasury Department in Sept. 1996, is intended to provide parties negotiating tax treaty issues with a flexible framework. While most provisions are consistent with prior law, some changes were made to competent authority procedures and reporting of bank information has been expanded. The treatment of fiscally transparent entities, such as partnerships, has been revised. In general, the model treaty continues to attack tax avoidance and limit double taxation.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1996
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Advance pricing agreements
Article Abstract:
The advance pricing agreement (APA) program has developed as a way for taxpayers to promote certainty and reduce liability risks associated with transfer pricing. Resolving methodology and arms-length valuation issues prospectively is more cost-effective for the taxpayer, the IRS and any other taxing authorities involved. The process involves a pre-filing conference, a formal request, negotiation, referral to the competent authority for any tax jurisdiction affected by the APA, and administration of the provisions that are agreed upon.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1997
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