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Diving into IRS’s Annual Report on Advance Pricing Agreements: Can APMA Overcome Its Sisyphean Task?

April 13, 2022 By Alston & Bird Federal & International Tax Group

Despite adding personnel and making a concerted effort to speed up the advance pricing agreement process, the Advance Pricing and Mutual Agreement Program (APMA) faces challenges with the mounting demand. Our International Tax Group breaks down the hurdles for APMA and identifies important trends companies negotiating APAs should keep in mind. APMA staff increased 21% last year, but median completion time for an APA increased to 35 months (up from 33 months in 2020) APMA would need more than three years to work through its existing inventory of bilateral APAs at its current processing rate [...]Read more

Filed Under: International - Transfer Pricing, International Tax Advisory Tagged With: Advance Pricing Agreements, Advance Pricing and Mutual Agreement Program, APA, APMA, Bilateral APA, covid-19, international, IRS, Tax, transfer pricing, Unilateral APA

Testing for COVID and Your Kits for Free: Expanded Coverage of OTC COVID-19 Test Kits and Developments in Preventive Care

February 14, 2022 By Alston & Bird Tax Team

Have questions about the new Frequently Asked Questions for group health plans’ coverage of over-the-counter COVID-19 test kits? Our Employee Benefits & Executive Compensation Group addresses key provisions of the extensive requirements for plans and issuers. Plans have a pair of safe harbors to limit reimbursement to $12 per test and limit the number of tests available to eight per month (or 30 days) Plans have some flexibility to prevent fraud and offer education to participants Certain plans must provide preventive care for colonoscopies and contraceptive services Read the [...]Read more

Filed Under: Employee Benefits Tagged With: ACA, Centers for Medicare and Medicaid Services, covid testing, covid-19, COVID-19 diagnostics tests, DOL, HDHP, health plan coverage, HHS, HRA, HSA, IRS, Medicare Advantage, Original Medicare, OTC COVID-19 Tests, Plan amendments, safe harbor, Treasury

IRS APMA’s Results May Suggest COVID-19 Immunity

April 19, 2021 By Richard Slowinski and Stefanie Kavanagh

Our International Tax Group analyzes the report on the IRS’s Advance Pricing and Mutual Agreement Program and identifies important insights and trends for advance pricing agreements. Effects of the COVID-19 pandemic on APMA operations and staffingAPA demand and output, 2019 – 2020More challenges on the horizon Click here to read the full advisory. [...]Read more

Filed Under: International - Transfer Pricing, International Tax Advisory Tagged With: Advance Pricing and Mutual Agreement Program, Announcement and Report Concerning Advance Pricing Agreements, APA, APMA, covid-19, IRS, OECD, TPMs, transfer pricing methods

Borrowers Beware: Short Sales of Distressed Assets May Have Unfavorable Tax Consequences

March 23, 2021 By Jasper L. (Jack) Cummings, Jr. and Seth Buchwald

Beware of being shortsighted. Last week, our Federal Tax Group takes the long view for borrowers and their creditors seeking to use short sales to extricate themselves from nonrecourse debt. What is a short sale?Is the short sale one integrated transaction or two separate ones?Two federal court cases tell the story Read the full advisory here. [...]Read more

Filed Under: Federal Tax Advisory Tagged With: cancellation of indebtednes, CODI, covid-19, Fifth Circuit Court of Appeals, nonrecourse debt, Section 1001, Section 108, short sales, U.S. Tax Court

How to Price in a Pandemic: New OECD Guidance on Transfer Pricing Challenges Caused by COVID-19

December 29, 2020 By Richard Slowinski and Stefanie Kavanagh

Our International Tax Group examines how the Organisation for Economic Co-operation and Development’s new guidance reiterates the central role of the arm’s-length standard and provides guideposts for taxpayers and tax administrations as they analyze how the COVID-19 pandemic is affecting intercompany pricing. Comparability analysisLosses and the allocation of COVID-19 specific costsGovernment assistance programsAdvance pricing agreements Read the full advisory here. Alston & Bird has formed a multidisciplinary response and relief team to advise clients on the business and legal [...]Read more

Filed Under: International - Transfer Pricing, International Tax Advisory Tagged With: APA, BEAT, CARES Act, covid-19, MNE, multinational enterprise, OECD, Organisation for Economic Co-operation and Development

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