Changes to the Internal Revenue Service’s advance pricing agreement program look to be on the horizon following the second public meeting on the subject of APAs this month, it has emerged.
According to reports in the US media, Hal Hicks, the IRS's international associate chief counsel, who presided over the public meeting, is said to be “definitely interested” in a number of changes that can be made to the program, which has been criticized by tax practitioners for its inflexibility.
It is believed by APA program director Matthew Frank that IRS Chief Counsel Donald Korb anticipates changes to the program will be made within a “very short time frame”.
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