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 ³ 401

Filed 2000–2013 459 993 3 1455

Filed in 2014 31 74 3 108

Total Filed 1991–2014 1964

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, 2014, APMA had received 33 user fee filings in addition to the 108 complete APA applications.

3The 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 1991–2013 489 797 14 1300

Total Executed in 2014 20 81 0 101

Total Executed 1991–2014 509 878 14 1401

Total Pending 62 268 6 336

Renewals Executed in 2014 9 39 0 48

Renewals Pending 28 119 2 149

Of the 101 agreements executed in 2014, 52 of the agreements (51 percent) were new APAs ( i.e., not a renewal of a prior APA). This was an increase from the 45 (47 percent) new APAs executed in 2013.

As the chart above illustrates, more than half of the total number of bilateral APAs executed in 2014 involved the United States entering into mutual agreements with Japan and Canada.

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There was no material change in the number of pending APAs between 2013 and 2014. Japan and Canada continued to account for more than half of the pending bilateral APAs in 2014.

Table 3: APAs Revoked or Cancelled and Applications Withdrawn § 521(b)(2)(C)(vii)

Unilateral Bilateral Multilateral Total

Revoked or Cancelled 2014 0 0 0 0

Total Revoked or Cancelled 1991–2014 11

Applications Withdrawn in 2014 0 1 0 1

Total Applications Withdrawn 1991–2014 190

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

Industry

Manufacturing 48

Wholesale/Retail Trade 22

Services 11

Management 9

Finance, Insurance and Real Estate 5

All Other Industries 6

4APAs finalized or renewed are the same as APAs executed.

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Table 4a: Manufacturing APAs Finalized or Renewed

Manufacturing

Computer and Electronic Products 13

Machinery 8

Miscellaneous Manufacturing 8

Electrical Equipment, Appliance and Components 8

Chemicals 6

All Other Types of Manufacturing 5

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

Wholesale/Retail Trade

Merchant Wholesalers, Durable Goods 14

Merchant Wholesalers, Nondurable Goods 7

All Other Types of Other Wholesale/Retail Trade 1

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