USA Law and Practice Contributed by: Devon M. Bodoh, Joseph M. Pari and Blake D. Bitter, Weil, Gotshal & Manges LLP
9.2 Other Mechanisms Large corporate taxpayers can participate in the Compliance Assurance Process, which offers real- time issue resolution between taxpayers and the IRS prior to filing a tax return. Other co-operative compli - ance programmes include: the Pre-Filing Agreements Programme(for resolving issues with the IRS prior to filing a tax return), the Industry Issue Resolution Pro - gramme (under which the IRS issues guidance resolv - ing frequently disputed issues) and various other dis - pute resolution and settlement programmes exist. Additionally, taxpayers may seek taxpayer-specific guidance regarding transactions through a private letter ruling request programme at the IRS.
a taxpayer and the IRS enter into an APMA, the US competent authority will, upon a request by the tax - payer, attempt to negotiate a bilateral advance pricing agreement with the competent authority of the treaty country that would be affected by the transfer pric - ing methodology. The IRS has encouraged taxpayers to seek such bilateral advance pricing agreements through the US competent authority.
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