What You Need to Know About the New IRS Approach to Approving Requests for Advance Pricing Agreements and Renewals

The Tax Practices of Holland & Knight and Simmons & Simmons invite you to a joint webinar focusing on the recent IRS Interim Guidance on the Review and Acceptance of Advance Pricing Agreement (APA) Submissions.

The guidance, issued on April 25, 2023, requires IRS personnel who review APA requests to apply new selectivity criteria to determine whether an APA request should be accepted or, if not, whether an alternative transfer pricing workstream, such as the International Compliance Assurance Program (ICAP) or a joint audit, should be proposed to best resolve a transfer pricing issue for taxpayers and the IRS. The Interim Guidance reflects a marked change in past practices dealing with the acceptance of APA requests.

Topics covered:

• How transfer pricing issues are resolved
• Current APA request practices
• The Interim Guidance – reasons for issuance, what it provides and how it works
• How a taxpayer should proceed under the Interim Guidance if it would like to pursue a unilateral, bilateral or multilateral request for an APA, or a renewal
• How transfer pricing practitioners in Europe view the Interim Guidance
• How the Interim Guidance selectivity criteria interrelates with criteria in Europe

Speakers:

James Dawson  |  Partner, Holland & Knight, West Palm Beach
Joshua Odintz  |  Partner, Holland & Knight, Washington, D.C.
Alan Winston Granwell  |  Of Counsel, Holland & Knight, Washington, D.C.
Monique van Herksen  |   Partner, Simmons & Simmons, Amsterdam
Clive Jie-A-Joen  |  Counsel, Simmons & Simmons, Amsterdam

Continuing Education Credits

Please note: Certificates of attendance will be provided upon request for attendees to self-apply for CPA credit.

Continuing Legal Credits (CLE)

Holland & Knight will apply for CLE credit based on attendee requests. Some programs may not be awarded CLE credits because of content or jurisdictional restrictions. CLE accreditation is sought after the completion of the program, and the approval process can be lengthy in some jurisdictions. Holland & Knight is an approved CLE provider in several jurisdictions, including California, Georgia, Illinois, New York, Pennsylvania and Texas. For New York attorneys, this program's format qualifies for CLE for transitional (newly admitted) and experienced attorneys