Draft Guidance Aims to Create Greater Transparency in MAPs, APAs

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The Internal Revenue Service released a pair of long-awaited and significantly revised draft revenue procedures governing the advance pricing and mutual agreement processes.
Michael Danilack, IRS deputy commissioner (International), said the agency is seeking comment on the Nov. 22 proposed revisions, which he described as “forward-looking” and reflective of a “reshaping of the competent authority program” with an emphasis on greater transparency and an effort to be more “interactive” and “accommodating” for taxpayers.
Notice 2013-78 , dealing with MAP applications to the U.S. competent authority, supersedes Rev. Proc. 2006-54 (223 DTR G-1, 11/20/06).

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