Tax News

CCH (cch.taxgroup.com) reports:

The IRS has updated its procedures with respect to securing an advance pricing agreement (APA) from the APA Program within the Office of Associate Chief Counsel (International). Through the APA Program, the IRS offers taxpayers the opportunity to reach agreement in advance of filing a tax return on the appropriate transfer pricing method to be applied to related-party transactions. Rev. Proc. 2006-9, 2006-1 CB 278, is modified effective June 9, 2008.
The IRS has added a process whereby the IRS and taxpayers may resolve other issues arising under certain income tax treaties, the Internal Revenue Code or the income tax regulations, for which transfer pricing principles may be relevant. Examples of such issues include attribution of profits to a permanent establishment under an income tax treaty, determining the amount of income effectively connected with the conduct by the taxpayer of a trade or business within the United States, and determining the amounts of income derived from sources partly within and partly without the United States, as well as related subsidiary issues.
Rev. Proc. 2008-31, 2008FED ¶46,437
Other References:
Code Sec. 482
CCH Reference - 2008FED ¶22,283.025
CCH Reference - 2008FED ¶22,283.103
CCH Reference - 2008FED ¶22,283.1036
CCH Reference - 2008FED ¶22,283.308
Code Sec. 894
CCH Reference - 2008FED ¶28,815.09
Code Sec. 7172
CCH Reference - 2008FED ¶41,090.65
Statement of Procedural Rules Sec. 601
CCH Reference - 2008FED ¶43,360.40
CCH Reference - 2008FED ¶43,360.42
Tax Research Consultant
CCH Reference - TRC INTL: 15,200