Part III. General Descriptions Of APAs Executed In 2017

This Announcement is issued pursuant to § 521(b) of Pub. L. 106-170, the Ticket to Work and Work Incentives Improvement Act of 1999, which requires the Secretary of the Treasury to report annually to the public concerning advance pricing agreements (APAs) and the Advance Pricing and Mutual Agreement Program (APMA Program), formerly known as the Advance Pricing Agreement Program (APA Program). The first report covered calendar years 1991 through 1999. Subsequent reports covered each calendar year 2000 through 2016 separately. This nineteenth report describes the experience, structure, and activities of the APMA Program during calendar year 2017. It does not provide guidance regarding the application of the arm’s length standard. Read More

IR-2018-82, April 2, 2018

WASHINGTON ― The Treasury Department and the Internal Revenue Service (IRS) yesterday issued Notice 2018-28, which provides guidance for computing the business interest expense limitation under recent tax legislation enacted on Dec. 22, 2017.

In general, newly amended section 163(j) of the Internal Revenue Code imposes a limitation on deductions for business interest incurred by certain large businesses. For most large businesses, business interest expense is limited to any business interest income plus 30 percent of the business’ adjusted taxable income. Read More

This Announcement is issued pursuant to § 521(b) of Pub. L. 106-170, the Ticket to Work and Work Incentives Improvement Act of 1999, which requires the Secretary of the Treasury to report annually to the public concerning advance pricing agreements (APAs) and the Advance Pricing and Mutual Agreement Program (APMA Program), formerly known as the Advance Pricing Agreement Program (APA Program). The first report covered calendar years 1991 through 1999. Subsequent reports covered each calendar year 2000 through 2016 separately. This nineteenth report describes the experience, structure, and activities of the APMA Program during calendar year 2017. It does not provide guidance regarding the application of the arm’s length standard. Read More

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.
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WASHINGTON — The Internal Revenue Service is seeking qualified applicants for nomination to the Electronic Tax Administration Advisory Committee (ETAAC).

The ETAAC provides an organized public forum for discussion of electronic tax administration issues, such as prevention of identity theft and refund fraud in support of the overriding goal that paperless filing should be the preferred and most convenient method of filing tax and information returns. ETAAC members work closely with the Security Summit, a joint effort of the IRS, state tax administrators and tax industry to fight electronic fraud. Read More

The IRS recommends that taxpayers use the Withholding Calculator on IRS.gov to do a “paycheck checkup” to check that their employers withhold the correct amount of income tax from their paychecks.

The Withholding Calculator can help prevent employees from having too little or too much withheld from their paycheck. Having too little tax withheld can mean an unexpected tax bill or potentially a penalty at tax time in 2019. And with the average refund topping $2,800, some taxpayers might prefer to have less tax withheld up front and receive more in their paychecks. Read More

WASHINGTON –– The Internal Revenue Service is reminding victims of Hurricane Maria in the U.S. Virgin Islands and in the Commonwealth of Puerto Rico that filing and payment activities have been further postponed beyond Jan. 31, 2018.

The IRS extended tax deadlines for affected individuals and businesses until June 29, 2018, for the following localities:

  • In the U.S. Virgin Islands (starting Sept. 16, 2017): Islands of St. Croix, St. John and St. Thomas.
  • In Puerto Rico (starting Sept. 17, 2017): In any of the 78 municipalities.

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WASHINGTON — The Internal Revenue Service today reminded taxpayers that income from virtual currency transactions is reportable on their income tax returns.

Virtual currency transactions are taxable by law just like transactions in any other property. The IRS has issued guidance in IRS Notice 2014-21 for use by taxpayers and their return preparers that addresses transactions in virtual currency, also known as digital currency. Read More

WASHINGTON – The IRS, state tax agencies and the tax industry warned tax professionals to be alert to taxpayer data theft in the final weeks of the tax filing season. The Security Summit partners urged tax professionals to enhance their data safeguards immediately.

In recent days, the “New Client” scam has re-emerged, signaling ongoing attempts by cybercriminals to target tax professionals with spear phishing schemes. Read More

WASHINGTON —The Internal Revenue Service reminded taxpayers today that it’s not too late to contribute to an Individual Retirement Arrangement (IRA) and still claim it on a 2017 tax return. Anyone with an IRA may be eligible for a tax credit or deduction on their 2017 tax return if they make contributions by April 17, 2018.

This is the sixth in a series of nine IRS news releases called the Tax Time Guide, designed to help taxpayers navigate common tax issues. This year’s tax-filing deadline is April 17. Read More

Each and every taxpayer has a set of fundamental rights they should be aware of when dealing with the IRS. Explore your rights and obligations to protect them.

1. The Right To Be Informed

Taxpayers have the right to know what they need to do to comply with the tax laws. They are entitled to clear explanations of the laws and IRS procedures in all tax forms, instructions, publications, notices and correspondence. They have the right to be informed of IRS decisions about their tax accounts and to receive clear explanations of the outcomes. Read More