APA report reflects continued productivity of new program in resolving double taxation disputes

Tax Insights ()
​The IRS, through the Office of the Advance Pricing and Mutual Agreement (APMA) Program, on March 27 issued its 15th Annual Statutory Report (Announcement 2014-14 or the report) concerning Advance Pricing Agreements (APAs). This is the second APA report that the IRS has issued since the February 2012 formation of the new APMA Program, which has combined responsibility for APAs and Mutual Agreement Procedures (MAPs) pertaining to treaty issues resulting in double taxation.  The new report describes the experience, structure, and activities of the APMA Program solely with respect to APAs.