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Procedures for Advance Pricing Agreements …

1 Procedures for Advance Pricing Agreements Internal Revenue Code 482: Allocation of income and deductions among taxpayers Rev. Proc. 2015-41 section 1. PURPOSE, BACKGROUND, RULES OF CONSTRUCTION AND DEFINITIONS section 2. SCOPE AND GENERAL APPLICATION section 3. Procedures FOR FILING APA REQUESTS section 4. ACTIONS ON APA REQUESTS section 5. COORDINATION WITH REV. PROC. 2015-40 AND ROLLBACKS .. section 6. LEGAL EFFECT OF AN APA section 7. ADMINISTERING AN APA section 8. RENEWING AN APA section 9. DISCLOSURE section 10. EFFECT ON OTHER DOCUMENTS section 11. EFFECTIVE DATE section 12. PAPERWORK REDUCTION ACT section 13. DRAFTING INFORMATION APPENDIX. APA REQUEST REQUIREMENTS 2 section 1. PURPOSE, BACKGROUND, RULES OF CONSTRUCTION, AND DEFINITIONS .01 Purpose and Background. This revenue procedure provides guidance on the process of requesting and obtaining Advance Pricing Agreements from the Advance Pricing and Mutual agreement program ( APMA ), a constituent office of the competent authority, within the office of the Deputy Commissioner International, Large Business & International Division.

2 SECTION 1. PURPOSE, BACKGROUND, RULES OF CONSTRUCTION, AND DEFINITIONS .01 Purpose and Background.This revenue procedure provides guidance on the process of requesting and obtaining advance pricing agreements from the Advance

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