SECTION 1. PURPOSE

This revenue procedure updates and supersedes Revenue Procedure 91–22, 1991–1 C.B. 526, and informs taxpayers how to secure an advance pricing agreement (‘‘APA’’) from the Office of the Associate Chief Counsel (International) covering the prospective determination

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above, they do not permit logos on the substitute Form 1099 itself. See, e.g., § 1.6042–4(d)(2)(i).

The Service intends to amend the regulations to allow the use of certain logos and identifying slogans on substitute Forms 1099 required to be furnished to payees. The amended regulations generally will permit logos (including the name of the payor in any typeface, font, or stylized fashion and/or a symbolic icon) and identifying slogans, provided the logo or identifying slogan is used by the payor in the ordinary course of its trade or business. However, consistent with Congressional intent, the amended regulations will provide that use of a logo or identifying slogan must not make it less likely that a reasonable payee will recognize the importance of the payee statement for tax reporting purposes. Pending issuance of the amended regulations, the Service will not impose penalties in connection with a payor’s use on a payee statement of a logo or an identifying slogan that satisfies these requirements.

Public comment invited. The Service invites public comment on this matter. Written comments may be submitted by mail to:

Internal Revenue Service P.O. Box 7604 Ben Franklin Station Attn: CC:CORP:T:R (IA–Branch 1),

and application of transfer pricing methodologies (‘‘TPMs’’) for international transactions. An APA is an agreement between the Service and the taxpayer on the TPM to be applied to any apportionment or allocation of income, deductions, credits, or allowances between or among two or more organizations, trades, or businesses owned or controlled, directly or indirectly, by the same interests. The TPM thus represents the application to the taxpayer‘‘s specific facts and circumstances of the best method within the meaning of the income tax regulations under § 482 of the Internal Revenue Code (’’the regulations‘‘), as agreed pursuant to negotiations between the Service and the taxpayer.