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advance pricing agreement (APA)

New IRS report provides details on 2015 advance pricing agreements

New IRS report provides details on 2015 advance pricing agreements

Ann. 2016-12, 2016-16 IRB In an Announcement, IRS has released its seventeenth required report providing details on the experience, structure, and activities of the Advance Pricing and Mutual Agreement (APMA) Program. The number of new advance pricing agreements (APAs) executed decreased from 53 in 2014 to 44 in 2015, while the total number of all […]

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Washington Alert – DOJ continues foreign tax evaders; IRS webinar on changes in retirement plans; Advance Pricing and Mutual Agreement office (APMA) will begin accepting requests for bilateral advance pricing agreements (APAs) between the U.S. and India

Washington Alert – DOJ continues foreign tax evaders; IRS webinar on changes in retirement plans; Advance Pricing and Mutual Agreement office (APMA) will begin accepting requests for bilateral advance pricing agreements (APAs) between the U.S. and India

There will be no letup in the federal government’s ongoing campaign targeting U.S. taxpayers who hide foreign accounts and attempt to evade U.S. tax obligations, a key Justice Department (DOJ) official said on Jan. 29. In 2016, tax professionals will see “additional civil enforcement actions and ongoing and new criminal investigations and prosecutions,” Caroline Ciraolo, […]

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New guidance issued on requesting competent authority assistance under tax treaties

New guidance issued on requesting competent authority assistance under tax treaties

Rev Proc 2015-40, 2015-35 IRB In a Revenue Procedure, IRS has provided guidance on the process of requesting and obtaining assistance under U.S. tax treaties from the U.S. competent authority, acting through the Advance Pricing and Mutual Agreement (APMA) Program and the Treaty Assistance and Interpretation Team (TAIT) of the Deputy Commissioner (International), Large Business […]

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IRS provides procedures for requesting competent authority assistance under tax treaties

IRS provides procedures for requesting competent authority assistance under tax treaties

Rev Proc 2015-40, 2015-35 IRB In a Revenue Procedure, IRS has provided guidance on the process of requesting and obtaining assistance under U.S. tax treaties from the U.S. competent authority, acting through the Advance Pricing and Mutual Agreement (APMA) Program and the Treaty Assistance and Interpretation Team (TAIT) of the Deputy Commissioner (International), Large Business […]

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IRS provides updated procedures for advance pricing agreements

IRS provides updated procedures for advance pricing agreements

Rev Proc 2015-41, 2015-35 IRB In a Revenue Procedure, IRS has provided guidance on the process of requesting and obtaining advance pricing agreements (APAs) from the Advance Pricing and Mutual Agreement (APMA) program, a constituent office of the U.S. competent authority, within the office of the Deputy Commissioner International, Large Business & International Division. Guidance […]

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New IRS report provides details on 2014 advance pricing agreements

New IRS report provides details on 2014 advance pricing agreements

Ann. 2015-11, 2015-15 IRB   In an Announcement, IRS has released its sixteenth required report providing details on the experience, structure, and activities of the Advance Pricing and Mutual Agreement (APMA) Program. During 2014, the number of new APAs increased from 45 in 2013 to 52 in 2014, while the total number of all APAs […]

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More progress made on cross-border corporate tax pacts – U.S. IRS

More progress made on cross-border corporate tax pacts – U.S. IRS

More progress made on cross-border corporate tax pacts – U.S. IRS. (Reuters) – The U.S. Internal Revenue Service is making progress this year on minimizing quarrels with multinational corporations over “transfer pricing,” or taxing how companies value and move capital and assets across borders, a senior IRS official told Reuters. The agency has signed 115 […]

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Changes proposed in advance pricing agreement procedures

Changes proposed in advance pricing agreement procedures

In Notice 2013-79, 2013-50 IRB, IRS has requested public comment on a proposed revision to the procedural guidance issued to taxpayers on filing advance pricing agreement (APA) requests and on the administration of APAs. Background.  An APA generally combines a voluntary agreement between a taxpayer and IRS on an appropriate transfer pricing methodologies (TPMs) for […]

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Meet Paul Raymond

Meet Paul Raymond

Mr. Raymond is a sought after speaker in tax controversy law by many attorney, accountant, and business groups and at the request of the Internal Revenue Service, has presented programs at the IRS Nationwide Tax Forum, attended by tax professionals throughout the United States.

Additionally, he continues to be an active member in the Section of Taxation, American Bar Association, where he was the Past Chair of the Employment Taxes Committee.

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Member CA Bar Member Orange County Bar US Tax Court Attorney