IRS LB&I provides interim guidance to employees reviewing advance pricing agreement submissions

Tax News Update Email this document Print this document

May 2, 2023
2023-0789

The IRS Large Business & International Division (LB&I) has provided interim guidance in a "Memorandum for Treaty and Transfer Pricing Operations Employees" that includes processes to be followed in reviewing prefiling memoranda, advance pricing agreement (APA) requests and APA renewal requests.

Published by NTD’s Tax Technical Knowledge Services group; Carolyn Wright, legal editor

The information contained herein is general in nature and is not intended, and should not be construed, as legal, accounting or tax advice or opinion provided by Ernst & Young LLP to the reader. The reader also is cautioned that this material may not be applicable to, or suitable for, the reader's specific circumstances or needs, and may require consideration of non-tax and other tax factors if any action is to be contemplated. The reader should contact his or her Ernst & Young LLP or other tax professional prior to taking any action based upon this information. Ernst & Young LLP assumes no obligation to inform the reader of any changes in tax laws or other factors that could affect the information contained herein.

All rights reserved. No part of this document may be reproduced, retransmitted or otherwise redistributed in any form or by any means, electronic or mechanical, including by photocopying, facsimile transmission, recording, rekeying, or using any information storage and retrieval system, without written permission from Ernst & Young LLP.

EY US Tax News Update Master Agreement | EY Privacy Statement