12 August 2015
The IRS today released two revenue procedures that provide guidance regarding the advance pricing agreement (APA) program, and that offer guidance on the process for taxpayers to request and obtain the assistance of the U.S. Competent Authority under the U.S. network of income tax treaties.
Rev. Proc. 2015-41 [PDF 241 KB] is the IRS guidance with respect to advance pricing agreements (APAs).
The IRS also released Rev. Proc. 2015-40 [PDF 245 KB] as guidance on the process of requesting and obtaining assistance under U.S. tax treaties from the U.S. Competent Authority, acting through the Advance Pricing and Mutual Agreement Program and the Treaty Assistance and Interpretation Team of the Deputy Commissioner (International) Large Business and International Division of the Internal Revenue Service.