IRS Provides Statistics on Competent Authority Activity in 2013
On April 30, 2014, the Large Business and International Division of the IRS released statistics on activity in the Office of the United States Competent Authority (“USCA”) during 2013. In general, the statistics show the IRS’s increased resources devoted to the USCA have increased the number of cases resolved.
The USCA includes both the Advanced Pricing and Mutual Agreement (“APMA”) Program and the Treaty Assistance and Interpretation Team (“TAIT”). APMA has primary responsibility for cases arising under the business profits and associated enterprises articles of U.S. income tax treaties, while TAIT handles all other issues arising under U.S. income tax treaties. APMA resolved 159 cases in 2013. By comparison, APMA resolved 90 cases in 2012 and 137 cases in 2011. TAIT resolved 102 cases in 2013. By comparison, TAIT resolved 50 cases in 2012 and 104 cases in 2011. Average processing time for APMA cases has remained stable over the last several years, while average processing time for TAIT cases has dropped during that period.
In 2013, 20.2 percent of APMA cases (measured by total dollar adjustment) resulted in no relief to the taxpayer and approximately 14 percent of APMA cases (measured by total dollar adjustment) were either withdrawn by the taxpayer or by the initiating tax authority. Of the remaining cases (approximately 66 percent) the taxpayer received relief of some type. Similar statistics were not published for TAIT.
KEYWORD: IRS Reports and Statistics
Tax Insights Blog