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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

Has the Global Tax(man) Ended the “Race to the Bottom”? 136 Countries Agree to Overhaul International Corporate Tax System

October 15, 2021 By Richard Slowinski and Stefanie Kavanagh

Our International Tax Group analyzes the pillars of a new international corporate tax system, but one that faces some major hurdles. Pillar One: a new taxing right in the digital worldPillar Two: a global minimum tax rate of 15%The road(blocks) ahead Read the full advisory here. [...]Read more

Filed Under: International - Transfer Pricing, International Tax Advisory Tagged With: base erosion, base erosion and profit shifting, BEPS, Corporate tax rate, digitalization, Income Inclusion Rule, international, MLC, MNE, MNEs, OECD, Rome, Subject to Tax Rule, transfer pricing, Undertaxed Payment Rule, Washington D.C.

The Republican Tax Reform Framework: What It Says and What It Doesn’t

October 3, 2017 By Carolyn Smith

Tax reform is coming, and Republican leaders have published a framework that raises as many questions as it answers. Our Tax Policy & Regulation Team investigates what the Big Six reveal and—just as important—what they don’t.

Tax rates for corporations and pass-through entities
Shifting to a territorial tax system
Revenue raisers and budget impact

Read the full advisory here. [...]Read more

Filed Under: Tax Policy, Tax Reform Tagged With: budget impact, Corporate tax rate, expensing, international, pass-through entities, republican, revenue raisers, tax reform, Trump Tax Reform

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