Part I. The APMA Program – Structure, Composition, and Operation
[PUB. L. 106-170 § 521(b)(2)(A)]
In February 2012, the former APA Program was moved from the Office of Chief Counsel to the Office of Transfer Pricing Operations1 within the Large Business and International Division of the IRS and combined with the U.S. Competent Authority staff responsible for transfer pricing cases, thereby forming the APMA Program.
As of December 29, 2017, the APMA Program included 55 team leaders, 17 economists, and 10 senior managers organized into 10 groups (7 team leader groups and 3 economist groups). The APMA Program’s main office is in Washington, DC, and it also has a significant presence in San Francisco and the Los Angeles area.
On August 31, 2015, new revenue procedures governing MAP and APA applications were published in 2015-35 I.R.B. on pages 236 and 263, respectively. Revenue Procedure (Rev. Proc.) 2015-41 provides guidance and instructions on filing APA requests as well as guidance and information on the administration of APAs. Rev. Proc. 2015-41 updates and supersedes Rev. Proc. 2006-9, 2006-1 C.B. 278, as modified by Rev. Proc. 2008-31, 2008-1 C.B. 1133, which is also superseded. Rev. Proc. 2015-40 provides procedures and guidance on requesting assistance from the U.S. Competent Authority where the taxpayer believes that the actions of the United States or a treaty country result or will result in the taxpayer being subject to taxation not in accordance with the applicable U.S. tax treaty. Rev. Proc. 2015-40 updates and supersedes Rev. Proc. 2006-54, 2006-2 C.B. 1035.
The 2009 model APA agreement appears in this report as Appendix 1. In the fall of 2017, APMA solicited comments on a proposed major revision. A list of primary APMA contacts is available at https://www.irs.gov/businesses/corporations/apma-contacts.
Tom Kerester – TaxConnections Ambassador In Washington D.C. Reports On IRS Releases
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