The IRS on November 22 issued a proposed update and revision of the revenue procedure governing advance pricing agreements (APAs). The proposed revenue procedure was issued for the purpose of soliciting public comments and will not be finalized and effective until the comments are considered. Comments on the proposed revenue procedure are requested by March 10, 2014.
The proposed revenue procedure contains revisions that are intended to be practical as well as to reflect the recent structural changes in the Advance Pricing and Mutual Agreement (APMA) program. In particular, the stated goals of the proposed revenue procedure, as set forth in the preamble, are to "improve clarity, readability, and organization" of previous guidance, and to reflect the 2010 establishment of the Large Business & International Division and the 2012 consolidation of the APA program into the Office of Competent Authority, creating the APMA program.