Are Advance Pricing Agreements Binding Commitments?

Journal
Spencer, K.; Kelleher, M.
United States
International Transfer Pricing Journal 2013 (Volume 20), No. 2
FormatPDF
USD
50

A recent case in the US Tax Court has the potential to severely damage the Internal Revenue Service’s advance pricing agreement programme. The case concerns the unilateral termination by the IRS of a taxpayer’s APAs, and the taxpayer’s efforts to compel the IRS to honour the APAs as binding contracts.