Clean-up on Aisle 10: Spring Cleaning for Advance Pricing Agreements

With the potential for a partial overhaul of the international tax provisions of the Tax Cuts and Jobs Act, as evidenced by the Senate Finance Committee’s hearings held on March 25, 2021, now’s the time to evaluate your company’s advance pricing and other transfer pricing agreements.

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Related Content

• I.R.C. Section 250: Proposed and Final Regulations Explained
• Review this practice note to gain perspective on I.R.C. Section 250 and the changes made by the Tax Cuts and Jobs Act.
• Transfer Pricing Tax Fundamentals
  Learn the fundamental issues of transfer pricing, including U.S. transfer pricing rules and regulations, transfer pricing methods, accuracy-related penalties, documentation requirements, and advance pricing agreements (APA).
• Treatment of GILTI State Law Survey
  Seize the opportunity to reference our 50-state survey summarizing the laws regarding the treatment of global intangible low-taxed income (GILTI) for state corporate income tax purposes.

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• Tax Key Legal Development Tracker (Federal)
  Stay informed on new federal tax developments:
  • Business Entities. Review the tax changes made by the American Rescue Plan Act of 2021, including (1) extension of the I.R.C. Section 461(l) limitation on excess business losses of noncorporate taxpayers through 2027, (2) provision of additional relief for qualified opportunity funds (QOFs) under I.R.C. Section 7508A, and (3) its permanently striking I.R.C. Section 864(f), reducing possible negative revenue effects and curtailing the complexities of Section 864(f) which sourced taxable income to entities within and outside the United States. American Rescue Plan Act of 2021 (H.R. 1319).
  • Individual Income Tax.
    • Following its earlier extension of the individual tax filing deadline to May 17, 2021, the IRS announced that individuals have until that same date to meet certain deadlines, normally falling on April 15, such as making IRA contributions and filing certain claims for refund. R.S. Notice 2021-21.
    • The IRS has notified taxpayers that amounts paid for personal protective equipment for the primary purpose of preventing the spread of COVID-19, are amounts paid for medical care under I.R.C. § 213(d). The IRS therefore confirms that these amounts are qualified medical expenses eligible to be paid or reimbursed under health flexible spending arrangements (health FSAs) and health savings account (HSAs). I.R.S. Announcement 2021-7.
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