On March 27, 2025 the IRS’s Advance Pricing Mutual Agreement Program (“APMA” or the “Program”) released Announcement 2025-13 which provides APMA’s annual Advance Pricing Agreement (“APA”) report (the “Report”). Key takeaways and our observations are noted here.Continue Reading 2024 APA Annual Report Shows Strong Year Despite Slight Decrease in Completions

On January 29, 2024, the OECD released the results and statistics for its growing International Compliance Assurance Program (“ICAP”).[1] The data spans the life of the ICAP program, dating back to the first pilot program that began in January 2018, through its full program operations as of October 2023. In all, the statistics generally suggest that the program has been efficient and productive, with most participants receiving mostly low-risk outcomes from tax administrations.Continue Reading ICAP: Life in the Fast Lane