TEI Comments on Revisions to APA Revenue Procedure
On March 10, 2014, TEI submitted comments to the IRS regarding Notice 2013-79, which proposes substantial revisions to Revenue Procedure 2006-9 for requesting advanced pricing agreements (APA) from the IRS. TEI’s comments focused on, among other things, the volume of information required to be submitted to the IRS under the proposed procedure, the pre-filing process, and Institute concerns with the authority of the IRS’s advanced pricing and mutual agreement program to expand the scope of an APA request.