IRS practice units on apas - KPMG Global
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IRS practice units on APAs for tangible goods transactions

IRS practice units on APAs (United States)

The IRS Large Business and International (LB&I) division publicly released two “practice units” that provide guidance concerning an advance pricing agreement (APA) for inbound and outbound transactions involving tangible goods. The practice units are part of a series of IRS examiner “job aides” and training materials intended to describe for IRS agents leading practices about tax concepts in general and specific types of transactions.


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These two practice units focus on the pricing of tangible goods between related parties and specifically concerning the APA analysis when a U.S. affiliate is the manufacturer and the foreign affiliate is the distributor or when a U.S. affiliate is the distributor and the foreign affiliate is the manufacturer.

Read the practice units:

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