ContractAdvance Pricing Agreement • April 21st, 2016
Contract Type FiledApril 21st, 2016Advance Pricing Agreement (“APA”) pre-filing conferences provide taxpayers with a forum to receive the Advance Pricing and Mutual Agreement Program’s (“APMA’s”) preliminary views and guidance on potential APAs and APA-related issues. Pre-filing conferences are intended to lead to a more productive and efficient APA process for APMA and taxpayers who participate in them and subsequently elect to file an APA request. Therefore, taxpayers are invited, and in some cases required, to meet with the APMA in a pre-filing conference prior to filing an APA request. Pre-filing requirements are found in sections 3.02(3) through 3.02(7) of Revenue Procedure 2015-41. (All references to sections herein pertain to Revenue Procedure 2015-41, 2015-35 I.R.B.