Part II. APMA Program Statistical Data

[Pub. L. 106–170 § 521(b)(2)(C)(i–viii)]

Table 1: APA Applications Filed § 521(b)(2)(C)(i)

Unilateral Bilateral Multilateral Total Filed 1991–1999 ¹ 401

Filed 2000–2012 439 904 1 1344

Filed in 2013 20 89 2 111

Total Filed 1991–2013 1856

The 111 APA applications received during 2013, represent a slight decrease from the 126 received in 2012. The table above illustrates the number of applications filed per year; however, the table does not include situations in which the taxpayer has paid a user fee but has not yet submitted a substantially complete APA request. As of December 31, 2013, APMA had received 42 user fee filings in addition to the 111 complete APA applications.

Almost 75 percent of the bilateral applications filed in 2013 involved either Japan or Canada.

1The first APA Statutory Report, which compiled APA data from 1991–1999, did not report the cumulative number of applications for those years by submission type, so the cumulative totals cannot be reported in that manner.

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Table 2: Executed and Pending APAs § 521(b)(2)(C)(ii-vi)

Unilateral Bilateral Multilateral Total

Total Executed 1991–2012 450 692 13 1155

Total Executed in 2013 39 105 1 145

Total Executed 1991–2013 489 797 14 1300

Total Pending 51 277 3 331

Renewals Executed in 2013 27 49 1 77

Renewals Pending 20 126 1 147

The APMA Program increased the number of APAs executed in its second year. The 145 APAs executed in 2013 surpassed the previous record of 140 executed agreements set in 2012. Of the 145 agreements executed in 2013, 68 of the agreements (47 percent) were new APAs ( i.e., not renewal APAs), an increase from the 57 (41 percent) new APAs executed in 2012.

As the chart above illustrates, more than half of the total number of bilateral APAs executed in 2013 involved the United States entering into a mutual agreement with Japan. Canada’s 19 percent also represents a significant portion of the bilateral agreements.

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The number of pending APAs decreased in 2013, primarily due to increased efficiencies within the new APMA Program. While the number of pending APAs at the end of 2013 was still higher than in some of the prior years reflected in the graph above, APMA’s streamlining of internal processes and implementation of new procedures are expected to result in a continued decrease in the pending inventory in future years.

Table 3: APAs Revoked or Cancelled and Applications Withdrawn § 521(b)(2)(C)(vii)

Unilateral Bilateral Multilateral Total

Revoked or Cancelled 2013 0 0 0 0

Total Revoked or Cancelled 1991–2013 11

Applications Withdrawn in 2013 3 6 0 9

Total Applications Withdrawn 1991–2013 189

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Table 4: APAs Finalized or Renewed ² by Industry § 521(b)(2)(C)(viii)

Industry

Wholesale/Retail Trade 60

Manufacturing 51

Services 11

Natural Resources and Transportation 9

All Other Industries 14

Table 4a: Manufacturing APAs Finalized or Renewed

Transportation Equipment 15

Chemicals 10

Computer and Electronic Products 9

Miscellaneous Manufacturing 8

Fabricated Metal Products 4

Other Manufacturing 5

2APAs finalized or renewed are the same as APAs executed.

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Table 4b: Wholesale/Retail Trade APAs Finalized or Renewed

Wholesale/Retail Trade

Merchant Wholesalers, Durable Goods 33

Merchant Wholesalers, Nondurable Goods 7

General Merchandise Stores 7

Wholesale Electronic Markets and Agents and Brokers 4

Other Wholesale/Retail Trade 9

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