Announcement 2024-16, page 909.

This Announcement is issued pursuant to § 521(b) of Pub. L. 106-170, the Ticket to Work and Work Incentives Improvement Act of 1999, which requires the Secretary of the Treasury to report annually to the public concerning advance pricing agreements (APAs) and the Advance Pricing and Mutual Agreement Program (APMA Program), formerly known as the Advance Pricing Agreement Program (APA Program). This twenty-fifth report describes the experience, structure, and activities of the APMA Program during calendar year 2023.

REG-117542-22, page 942. This Notice of Proposed Rulemaking revises the regulations pertaining to the advance notice to be provided to taxpayers prior to IRS contact with third parties to conform to the new statutory language of section 7602(c) enacted as part of the Taxpayer First Act of 2019 (TFA), Public Law 116-25 (133 Stat. 981). The proposed regulations also provide, pursuant to the Secretary’s authority in section 7602(c)(1)(B), exceptions to the 45-day advance notice requirement where delaying contact with third parties for 45 days after providing notice to the taxpayer would impair tax administration.