Date: Thursday, June 15, 2023
Time: 11:00 AM - 12:30 PM ET
The IRS issued Interim Guidance on April 25, 2023, that requires IRS Large Business and International Division (LB&I) 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 request
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