TEI Comments on Revisions to APA Revenue Procedure

On March 10, 2014, TEI submitted comments to the IRS regarding Notice 2013-79, which proposes substantial revisions to Revenue Procedure 2006-9 for requesting advanced pricing agreements (APA) from the IRS. TEI’s comments focused on, among other things, the volume of information required to be submitted to the IRS under the proposed procedure, the pre-filing process, and Institute concerns with the authority of the IRS’s advanced pricing and mutual agreement program to expand the scope of an APA request.

TEI’s comments were prepared under the aegis of TEI’s U.S. International Tax Committee, whose chair is Jim Silvestri of Capsugel. Benjamin R. Shreck, TEI Tax Counsel, coordinated the preparation of TEI’s comments.

Download the submission.