Rocco Femia discusses advisability of pursuing Advance Pricing Agreements (APAs) with the IRS given the recent increase in processing times. "Taxpayers, advisers, and governments, as well as the IRS, have become frustrated with how long these cases can take," says Femia. Without an APA, companies may try do the right thing, but "there’s no guarantee, even if the taxpayer is very responsible in determining the right price, that tax authorities will agree to that [determination]," says Femia.

For its part, the IRS has increased its staff and reorganized earlier this year, merging the Office of the U.S. Competent Authority, which handles transfer-pricing cases with foreign jurisdictions, with its APA Program. "Any changes that reduce [processing times] -- whether because of an increase in staffing or better execution -- … would be beneficial" to taxpayers, Femia said.