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The IRS's Advance Pricing and Mutual Agreement Program (APMA) recently announced the release for public discussion of a draft template for use in drafting an advance pricing agreement (APA). The draft APA template includes numerous detailed terms, requirements and definitions that, if included in the final template will require careful attention by APA taxpayers to ensure that they work correctly in each taxpayer's particular circumstances.

For further details please read our TP Tax Insights article.