APA Move Could Mean More Efficiency, Less Independence, Practitioners Say

With the Advance Pricing Agreement Program’s inventory at an all-time high and a four- to six-month wait for work to begin on cases, practitioners seem less opposed to a possible combining of the Internal Revenue Service’s Competent Authority and APA staff than they were when the issue was raised in both 1993 and 2000.

Some pointed out that moving the program out of the Office of the Associate Chief Counsel (International) into a newly organized international unit in the Examination division would allow for more efficient case processing as well as give the IRS the ability to hire more staff. However, others voiced the concern, also expressed in past years, of whether the APA Program could maintain its independence if became part of the U.S. Competent Authority. Enjoying this article? To continue reading you need to take out a FREE trial to the Transfer Pricing Library.




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