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IRS completed 43 advance pricing agreements in 2011, down from a total of 69 in 2010, while the number of pending requests increased from 350 in 2010 to 445 in 2011, according to the service's annual statutory report on APAs. IRS officials attribute the decline in case closures to the amount of staff time directed toward creating the new Advance Pricing and Mutual Agreement (APMA) Program, a merger of the former APA Program with the portion of the Office of U.S. Competent Authority that resolves transfer pricing cases under U.S. treaty mutual agreement procedures. The tasks of recruiting, interviewing, and training new staff members represented a “huge commitment by the very people who would otherwise be processing cases,” says Samuel Maruca, director of transfer pricing operations with IRS.
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