IRS focuses on permanent establishment issues; creates combined APA-MAP office

August 2011

Overview

The creation last year of the IRS Large Business and International Division (LB&I) was prompted in great part by the desire of the IRS to improve its administration of international tax issues. Since then, the division has undertaken important initiatives of tremendous importance to large multinational corporations (MNCs). One initiative involves the IRS administration of permanent establishment (PE) issues; another addresses the IRS Advance Pricing Agreement (APA) Program and the Mutual Agreement Procedure (MAP) for transfer pricing issues.

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