US IRS updates APA, MAP parameters

On October 28, the US Internal Revenue Service (IRS) announced that it is updating parameters that the Advance Pricing and Mutual Agreement program (APMA) will follow in implementing resolutions it has reached on behalf of U.S. taxpayers in mutual agreement procedure and advance pricing agreement cases negotiated under US income tax treaties. 

The updates significantly curtail so-called “telescoping” of the results of these cases into current tax years; US taxpayers will generally be required to amend the applicable year’s federal income tax return to reflect the changes in taxable income per competent authority resolutions instead of reflecting the changes to taxable income in current tax years.  

The update reflects the IRS’s efforts to promote compliance with changes brought to US tax law by the Tax Cuts and Jobs Act and its many interlocking provisions that require careful determination of a US taxpayer’s taxable income and tax attributes.
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