The IRS Large Business and International (LB&I) division publicly released two “practice units” that provide guidance concerning an advance pricing agreement (APA) for inbound and outbound transactions involving tangible goods. The practice units are part of a series of IRS examiner “job aides” and training materials intended to describe for IRS agents leading practices about tax concepts in general and specific types of transactions.
These two practice units focus on the pricing of tangible goods between related parties and specifically concerning the APA analysis when a U.S. affiliate is the manufacturer and the foreign affiliate is the distributor or when a U.S. affiliate is the distributor and the foreign affiliate is the manufacturer.
Read the practice units:
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