IRS proposes changes to Competent Authority and APA procedures: comments requested by 20 March 2014
By Michael F Patton
The Internal Revenue Service (IRS) has published for comment two draft revenue procedures that change the existing process for US taxpayers requesting Competent Authority relief under the mutual agreement procedures (MAPs) and other provisions of US income tax treaties (or similar agreements) and that would change the procedures applicable to advance pricing agreements (APAs).
Notice 2013-78 proposes changes that would replace Revenue Procedure 2006-54 (MAP). Notice 2013-79 proposes changes that would replace Revenue Procedure 2006-9 and 2008-31 (APAs).
The proposed revisions to the MAP procedures are generally a greater departure from current procedures than are the proposed changes to current APA procedures. The IRS has requested taxpayer comments on the proposed changes by 20 March 2014…
If you are registered and logged in to the site, click on the link below to read the rest of the DLA Piper briefing. If not, please register or sign in with your details below.
Sign in or Register to continue reading this article
It's quick, easy and free!
It takes just 5 minutes to register. Answer a few simple questions and once completed you’ll have instant access.Register now
Why register to The Lawyer
In-depth, expert analysis into the stories behind the headlines from our leading team of journalists.
Identify the major players and business opportunities within a particular region through our series of free, special reports.
Receive your pick of The Lawyer's daily and weekly email newsletters, tailored by practice area, region and job function.
More relevant to you
To continue providing the best analysis, insight and news across the legal market we are collecting some information about who you are, what you do and where you work to improve The Lawyer and make it more relevant to you.
News from DLA Piper
News from The Lawyer
Briefings from DLA Piper
The Australian Taxation Office released a draft ruling on the Goods and Services Tax treatment of bitcoin transactions on 20 August 2014.
DLA Piper’s ‘Life sciences: patent extension strategies and antitrust global update’ video covers global antitrust and competition issues including product hopping and reverse payment patents.
Analysis from The Lawyer
Regulators are ramping up the pressure in the aftermath of recession, leaving firms to compete for compliance and restructuring work
Shearman & Sterling is making its presence felt in the City, squaring up to magic circle firms and looking to muscle in on key relationships. Private equity house Bridgepoint is one outfit that has had its head turned by the US firm.