United States - Are Advance Pricing Agreements Binding Commitments?
- United States
- K. Spencer; M. Kelleher
- International Transfer Pricing Journal, 2013 (Volume 20), No 2
- 28 February 2013
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.