The Internal Revenue Service (IRS) has issued an annual review of its Advance Pricing and Mutual Agreement Program (APMA) that "describes the experience, structure, and activities of the APMA Program during calendar year 2020."

The report shows few major shifts in the number and types of APAs processed last year despite disruptions from the COVID-19 pandemic affecting both the agency and corporate participants. The processing time for APAs, however, dropped significantly last year.

The number of APA applications filed in 2020 was 121, or about the same number filed in 2019. The IRS executed 127 APAs in 2020, which was 7 more than in 2019. The median processing time for APAs in 2020 was reduced by 6 months to 32.7 months, down from 38.8 months in 2019.

​The IRS explains that the APMA report for 2020 includes the following information divided into three main sections:

• Part I includes information on the structure, composition, and operation of the APMA Program
• Part II presents statistical data
• Part III includes general descriptions of various elements of the APAs executed in 2020, including types of transactions covered, transfer pricing methods used, and completion time

The 69-page text of the APMA report is posted here.

Miller & Chevalier Coronavirus Task Force
The outbreak of COVID-19 is creating significant business and legal challenges for companies throughout the world. In response to client demand, the firm has formed an interdisciplinary task force to help businesses navigate these issues.

COVID-19 Resource Library
We also maintain a resource library of legislative responses and regulatory guidance related to COVID-19.

The information contained in this communication is not intended as legal advice or as an opinion on specific facts. This information is not intended to create, and receipt of it does not constitute, a lawyer-client relationship. For more information, please contact one of the senders or your existing Miller & Chevalier lawyer contact. The invitation to contact the firm and its lawyers is not to be construed as a solicitation for legal work. Any new lawyer-client relationship will be confirmed in writing.

This, and related communications, are protected by copyright laws and treaties. You may make a single copy for personal use. You may make copies for others, but not for commercial purposes. If you give a copy to anyone else, it must be in its original, unmodified form, and must include all attributions of authorship, copyright notices, and republication notices. Except as described above, it is unlawful to copy, republish, redistribute, and/or alter this presentation without prior written consent of the copyright holder.