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Announcement And Report Concerning Advance Pricing Agreements.pdf

po70328-announcement-2022-7-apa-report.pdf
Preview of Announcement and Report Concerning Advance Pricing Agreements
🔗 Source: irs.gov
📊 Size: 2.55 MB
👤 Author: Internal Revenue Service
⬇️ Downloads: 170

Summary

The 23rd annual report on the Advance Pricing and Mutual Agreement (APMA) Program, covering calendar year 2021, provides insights into the program's structure, activities, and statistics. Key points include:

- Program Structure: The APMA Program, formed in 2012, is part of the Large Business and International Division of the IRS. It consists of 80 team leaders, 25 economists, 9 managers, and 3 assistant directors, operating from offices in Washington, DC, and major cities across the U.S. It is governed by Revenue Procedure 2015-41.

- APA Applications and Executions:
- Total APA applications filed: 2,936 (1991-2021), with 145 in 2021.
- Total APAs executed: 2,191 (1991-2021), with 124 in 2021.
- Renewals executed in 2021: 78 (63% of all APAs executed in 2021).
- Pending APAs as of December 31, 2021: 461.

- Country Distribution: Japan and India were the top countries for bilateral APA requests and renewals in 2021.

- Revoked or Cancelled APAs and Withdrawn Applications: No APAs were revoked or cancelled in 2021. Six applications were withdrawn in 2021, with a total of 279 withdrawn since 1991.

- APMA Contacts: A list of primary APMA contacts is available at .

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Description

23rd annual report on APMA Program (2021); no new arm's length guidance.

Technical Information

  • File Format: PDF
  • File Size: 2.55 MB
  • Pages: 69
  • Language: EN
  • Author: Internal Revenue Service
  • Total Downloads: 170
  • Last Updated: 5 days ago

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