IRS moves APA program out of Chief Counsel's office; creates new Advance Pricing and Mutual Agreement Program

Tax Insights ()

On July 27, 2011, the Internal Revenue Service (IRS) announced that the Advance Pricing Agreement (APA) Program and the Tax Treaty Office staff who handle Mutual Agreement Procedure (MAP) transfer pricing cases, will be combined into one office in the Large Business & International (LB&I) Division's international operation. As a result, the APA Program will move from the IRS Office of Chief Counsel to LB&I. The new "Advance Pricing and Mutual Agreement Program" will be directed by one executive, and the office will be under the jurisdiction of the new IRS Transfer Pricing Director, Sam Maruca.