IRS Releases Two International Practice Units on APAs for Inbound and Outbound Tangible Goods Transactions

On November 6, 2017, the Internal Revenue Service (IRS) released two new International Practice Units (IPUs) relating to Advance Pricing Agreements (APAs) for inbound and outbound tangible goods transactions. The IPUs provide a summary of the APA process, the types of APAs, and the interpretation and impact of an APA. The IPUs focus on the APA analysis for inbound distributors and outbound distributors. As we have previously noted, this high-level guidance to field examiners signals the IRS’s continued focus on international tax issues.