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April 26, 2021

IRS extends time for submitting APA and MAP requests with e-signatures

The IRS has extended the date by which advance pricing agreement (APA) and mutual agreement procedure (MAP) requests may be filed electronically with digital signatures until December 31, 2021.

On April 15, 2021, the IRS released an updated memo on e-signature requirements. The new memo is the same as an earlier memo issued December 1, 2020 (which had an expiration date of June 30, 2021) (See Tax Alert 2020-1302).

Filing modifications

These modifications affect the procedures for filing MAP request documents under Revenue Procedure 2015-40 and for filing APA requests and annual APA reports under Revenue Procedure 2015-41.

Under the modifications, documents requiring the taxpayer's signature under Revenue Procedure 2015-40 or Revenue Procedure 2015-41 may be submitted instead with either (1) a scanned or photographed image of the taxpayer's signature or (2) the taxpayer's digital signature created using encryption techniques.

In addition, taxpayers may electronically file submissions required under Revenue Procedure 2015-40 or Revenue Procedure 2015-41 rather than submitting paper copies.


The IRS's ability to adapt to the virtual environment by recognizing electronic signatures when submitting MAP or APA documentation demonstrates the flexibility afforded taxpayers during this time. Multinational taxpayers should examine their own books and records for opportunities to benefit from the certainty that these types of agreements can provide.


Contact Information
For additional information concerning this Alert, please contact:
National Tax Department, International Tax and Transactions Services, Transfer Pricing
   • Ryan Kelly (
   • Tom Ralph (
   • Heather Gorman (
   • Matt Johnson (