Part I. The APMA Program – Structure, Composition, and Operation
Internal Revenue Bulletin 2024-16 · 2026-10-03 edition · updated 2026-10-04 · United States
[Pub. L. 106-170 § 521(b)(2)(A)]
In February 2012, the former APA Program was moved from the Office of Chief Counsel to the Office of Transfer Pricing Operations 1 within the Large Business and International Division of the IRS and combined with the U.S. Competent Authority staff responsible for transfer pricing cases, thereby forming the APMA Program (APMA).
As of December 31, 2023, APMA’s APA cases were handled by 70 team leaders, 29 economists, 12 managers, and 3 assistant directors. 2 Each assistant director oversees four managers who lead teams consisting of both team leaders and economists. APMA’s main office is in Washington, DC, and it also has offices in northern California, southern California, and the Atlanta, Boston, Chicago, Denver, Miami, New York, and Seattle metropolitan areas.
On August 31, 2015, the current revenue procedure governing APA applications was published in 2015-35 I.R.B. on page 263. Revenue Procedure (Rev. Proc.) 2015-41 provides guidance, information and instructions on APA requests and the administration of APAs. Rev. Proc. 2015-41 updates and supersedes Rev. Proc. 2006-9, 2006-1 C.B. 278, as modified by Rev. Proc. 2008-31, 2008-1 C.B. 1133, which is also superseded.
The model for APAs covered by Rev. Proc. 2006-9 was updated to serve as the current model APA for APAs covered by Rev. Proc. 2015-41. The model APA is included as Appendix 1 to this report. A list of primary APMA contacts is available at https://www.irs. gov/businesses/corporations/apma-contacts.
1 In 2017, Transfer Pricing Operations became Treaty & Transfer Pricing Operations (“TTPO”).
2 In late 2020, TTPO’s Treaty Assistance and Interpretation Team (TAIT) joined APMA, bringing the total number of groups in APMA to four. The three legacy APMA groups have primary responsibility for cases arising under the business profits and associated enterprises articles of U.S. tax treaties. TAIT endeavors to resolve competent authority issues arising under all other articles of U.S. tax treaties including issues arising under U.S. tax treaties relating to estate and gift taxes. As such, TAIT is separate from APMA’s APA program, and the total numbers of team leaders and managers handling APA cases do not include TAIT analysts and managers.
April 15, 2024 910 Bulletin No. 2024–16
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