Developing Improved Tactics for Advance Pricing Agreements to Decrease Negotiation Lead Time

Authors

Ryan Vines, Benjamin N. Cardozo School of Law

Abstract

This Note seeks to investigate the inefficiencies of the Advance Pricing Agreement negotiation process and how inequitable negotiations adversely affect the American taxpaying community, and small and medium sized corporations. The results of this investigation point to the necessity for the IRS to collect data and perform trend analyses. Although marginal improvements have been made by the Advance Pricing and Mutual Agreement ("APMA") Office, the data show that the real issues of Advance Pricing Agreement negotiations have yet to be resolved. The current practices and procedures of a typical Advance Pricing Agreement negotiation does not promote horizontal equity among taxpayers. These issues enable larger corporations to take advantage of our tax system and reap the benefits. Unless changes are made, these large corporations will continue to take advantage of a financial opportunity only they can take advantage of, which adversely affects U.S. taxpayers.

Disciplines

Criminal Law | Criminal Procedure | Dispute Resolution and Arbitration | International Trade Law | Law

Recommended Citation

Ryan Vines, Developing Improved Tactics for Advance Pricing Agreements to Decrease Negotiation Lead Time, 19 Cardozo J. Conflict Resol. 191 (2017).
Available at: https://larc.cardozo.yu.edu/cjcr/vol19/iss1/11