SECTION 3. MODIFICATION OF REV.

PROC. 2006–9

Section 2.01 of Rev. Proc. 2006–9 is modified to read as follows:

The APA Program provides a voluntary process whereby the Internal Revenue Service (“Service”) and taxpayers may resolve transfer pricing issues under Section 482 of the Internal Revenue Code (“Code”), the Income Tax Regulations under Section 482, and relevant income tax treaties to which the United States is a party in a principled and cooperative manner on a prospective basis. The APA program also provides a process whereby the Service and taxpayers may resolve other issues arising under certain

26 CFR 1.482–1: Allocation of income and deduc- tions among taxpayers.

Rev. Proc. 2008–31