IRS proposes changes to Competent Authority and APA procedures: comments requested by 20 March 2014

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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…

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