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Transfer Pricing Weekly Quotes Patricia Lewis Regarding IRS Proposals to Revise APA and MAP Procedures

April 3, 2014, Transfer Pricing Weekly

International Tax Review's Transfer Pricing Weekly spoke with Patricia Gimbel Lewis  concerning the recent IRS proposals to revise the advance pricing agreement and mutual agreement program procedures.  The proposed changes aim, among other things, to expand the role of the U.S. Competent Authority office, reduce inefficiencies, and increase standardization of applications.  The proposals have received mixed reactions as some feel they could increase burdens on the taxpayer.  For the complete article, please visit Transfer Pricing Weekly's website (subscription required).

Excerpt taken from the article.

"To the extent earlier USCA involvement results in the substantial reduction or elimination of double-tax cases, MAP applications would be reduced, though this may be wishful thinking; the opposite could well result," said Patricia Lewis of Caplin & Drysdale.

Lewis thinks there could be some hesitation in filing APA requests until the scope of the submission requirements is clarified. However, she believes this will be temporary.

"Taxpayers' continued desire for certainty for financial and accounting reasons should drive increased APA applications – especially if IRS-anticipated efficiencies in fact eventuate," said Lewis.


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