Part I. The APMA Program – Structure, Composition, and Operation
Internal Revenue Bulletin 2026-16 · 2026-10-03 edition · updated 2026-10-04 · United States
[Pub. L. 106-170 § 521(b)(2)(A)]
The Advance Pricing and Mutual Agreement Program (APMA) is part of the U.S. Competent Authority’s Office under Treaty & Transfer Pricing Operations (TTPO) within the Large Business and International Division of the IRS.
As of December 31, 2025, APMA’s APA cases were handled by a staff of 108, comprising 63 team leaders, 30 economists, 12 managers, and 3 assistant directors. 1 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, Florida, and the Boston, Chicago, Denver, New York City, and Seattle metropolitan areas. A list of primary APMA contacts is available at https:// www.irs.gov/businesses/corporations/apma-contacts.
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 Proc. 2008-31, 2008-1 C.B. 1133, which is also superseded.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 (instead of the model APA that had been issued with Rev. Proc. 2015-41). The model APA that is included as Appendix 1 to this report remains unchanged since last year’s report.
1 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 13, 2026 814 Bulletin No. 2026–16
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