The APA Program provides an alternative dispute resolution mechanism for taxpayers and the IRS to resolve complex international transfer pricing cases.
The Office of Chief Counsel provides legal guidance and interpretive advice to the IRS, Treasury and to taxpayers. Go to this page for Chief Counsel decisions, bulletins and notices.
Pursuant to the provisions of Temporary Regulation § 1.6043-4T(a), requiring reporting of certain acquisitions of control and substantial changes in capital structure, corporations can consent to the publication by the IRS of the information from their Form 8806.
The tax law starts with the Internal Revenue Code that is enacted by Congress. After the statute is enacted, the IRS issues regulations to help interpret and apply the law. Here's a place where you can learn more about IRS regulations.
LMSB Directives provide industry-related and administrative guidance to LMSB examiners to ensure consistent tax administration. The Directives do not establish Service position on legal issues and are not legal guidance.
The Treasury Department and IRS have released the instructions for Schedule M-3, "Net Income (Loss) Reconciliation for Corporations With Total Assets of $10 Million or More".