Advance pricing agreements in the United States: In a state of flux?

Extract: On July 27, 2011, the IRS announced a landmark change to the U.S. advance pricing agreement program.1 The APA program was to move from the Office of IRS Chief Counsel (where it had resided since the program’s inception in 1991) to an office under the transfer pricing director in the Large Business and International Division’s international operation. Here it would join the area of the U.S. competent authority (USCA), which dealt with the IRS’s mutual agreement procedure (MAP) program, responsible primarily for resolving transfer pricing disputes arising under income tax treaties negotiated by the United States and treaty partner countries.