Change Requests

Key Information

Previous ICR	202504-0938-012

Federal Register Notices

Authorizing Statutes

Abstract

The final rule "Patient Protection and Affordable Care Act; Annual Eligibility Redeterminations for Exchange Participation and Insurance Affordability Programs; Health Insurance Issuer Standards Under the Affordable Care Act, Including Standards Related to Exchanges", provides that a Marketplace may choose to conduct the annual redetermination process for a plan year (1) in accordance with the existing procedures described in 45 CFR 155.335; (2) in accordance with procedures described in guidance issued by the Secretary for the coverage year; or (3) using an alternative proposed by the Marketplace and approved by the Secretary. The guidance document "Guidance on Annual Redeterminations for Coverage for 2015" contains the procedures that the Secretary is specifying for the 2015 coverage year, as noted in (2) above. These procedures will be adopted by the Federally-facilitated Marketplace. Under this option, the Marketplace will provide three notices. The final rule also amends the requirements for product renewal and re-enrollment (or nonrenewal) notices to be sent by Qualified Health Plan (QHP) issuers in the Exchanges and specifies content for these notices. The accompanying guidance document "Form and Manner of Notices When Discontinuing or Renewing a Product in the Group or Individual Market" provides standard notices for product discontinuation and renewal to be sent by issuers of QHPs and issuers in the individual market. Issuers in the small group market may use the draft Federal standard small group notices released in the June 26, 2014 bulletin "Draft Standard Notices When Discontinuing or Renewing a Product in the Small Group or Individual Market", or any forms of the notice otherwise permitted by applicable laws and regulations. States that are enforcing the Affordable Care Act may develop their own standard notices, for product discontinuances, renewals, or both, provided the State-developed notices are at least as protective as the Federal standard notices.

Key Information

Previous ICR	202112-3072-003

Federal Register Notices

Authorizing Statutes

Abstract

Section 16 of the Shipping Act of 1984, 46 U.S.C. § 40103, authorizes the Federal Maritime Commission (“Commission”) to exempt by order or regulation “any class of agreements between persons subject to this [Act] or any specified activity of those persons from any requirement of this [Act] if the Commission finds that the exemption will not result in substantial reduction in competition or be detrimental to commerce. The Commission may attach conditions to any exemption and may, by order, revoke an exemption.” The Commission added 46 CFR 532 to exempt non-vessel-operating common carriers (NVOCCs) from the more stringent tariff rate publication requirements of the Shipping Act of 1984 and related provisions of the Commission’s regulations to permit them to enter into negotiated rate arrangements (NRAs) with shippers.76 FR 11351 (March 2, 2011). The Commission subsequently extended the tariff rate publication exemption contained in 46 CFR part 532 to foreign based unlicensed NVOCCs as well. 78 FR 42886 (July 10, 2013). The exemption is conditioned upon the NVOCC including a prominent notice invoking the exemption in its electronically published rules tariff and indicating their intention to the Commission. In addition, NVOCCs must maintain original NRAs and associated records for 5 years in a format easily produced to the Commission and furnish those records promptly upon request from the Commission. An NVOCC invoking the exemption must: Include its rates in a tariff open to public inspection (46 CFR 532.3(a)(1); Comply with 46 USC 40501(d) and (e) (46 CFR 532.3(b) and (c)); Comply with 46 USC 40503 (46 CFR 532.3(d); Adhere to the prohibitions in 46 USC 41104(a)(2)(A) (46 CFR 532.3(e); Include its rates in a tariff open for public inspection in an automated tariff system (46 CFR 532.3(f); Comply with 46 CFR 520.4(a)(4), 520.4(f), 520.6(e), 520.7(c) and (d), 520.8(a), 520.12, and 520.14 (46 CFR 523..3(g); Ensure their NRA meets the requirements of 46 CFR 532.5; Indicate their intention to the Commission and the public to invoke the exemption by a prominent notice in its rules tariff (46 CFR 532.6); Maintain original NRAs in a readily accessible and retrievable manner for 5 years from the completion date of performance of the NRA (46 CFR 532.7; and Promptly respond to requests by the Commission for those records (46 CFR 532.7).

Key Information

Previous ICR	202112-3072-002

Federal Register Notices

Authorizing Statutes

Abstract

Section 16 of the Shipping Act of 1984, 46 U.S.C. 40103, authorizes the Federal Maritime Commission to exempt by rule “any class of agreements between persons subject to this Act or any specified activity of those persons from any requirement of this Act if it finds that the exemption will not result in substantial reduction in competition or be detrimental to commerce. The Commission may attach conditions to any exemption and may, by order, revoke any exemption.” The Commission added 46 CFR 531 to exempt non-vessel-operating common carriers (NVOCCs) from the more stringent tariff rate publication requirements of the Shipping Act of 1984 and related provisions of the Commission’s regulations to permit them to enter into contracts with shippers similar to ocean common carrier service contracts. 69 FR 75850 (Dec. 20, 2004). The exemption was conditioned upon the filing of NVOCC service arrangements (NSAs) with the Commission by the NVOCC offering the service; publication of the essential terms of NSAs; and confidential treatment of NSAs. In addition, NVOCCs were required to maintain NSAs and associated records for five years. In 2018, the Commission provided further relief of regulatory burdens on NVOCC by removing the NSA filing requirements effective August 22, 2018. (83 FR 34780) The filing exemption is conditioned upon the licensed NVOCC including a prominent notice invoking the exemption in its electronically published rules tariff and indicating their intention to the Commission. NVOCCs must continue to maintain original NSAs and associated records for 5 years in a format easily produced to the Commission, and provide those records promptly upon request from the Commission. NVOCCs wishing to invoke the exemption must: Including the terms listed in 46 CFR 531.6(b) in their NSA; Abide by the prohibitions in 46 CFR 531.6(c); Assign a unique NSA number to each agreement (46 CFR531.6(d)); Provide electronic access to its rules tariffs to the public free of charge (46 CFR 531.4(a); Indicate their intention to invoke the exemption by including a prominent notice on its rules tariff (46 CFR 531.4(b); Maintain original NSAs, amendments, and their associated records for five years from the termination of each NSA in a format that is readily available and useable by Commission (46 CFR 531.12(a)); and Provide those records to the agency upon a written request from the Commission (46 CFR 531.12(b)).

Key Information

Previous ICR	202104-3072-001

Federal Register Notices

Authorizing Statutes

Abstract

Section 40502 of title 46 of the United States Code requires ocean common carriers and agreements among such carriers to file their service contracts confidentially with the Commission and to publish certain essential terms of those service contracts. Service contracts are written contracts between one or more shippers or a shippers’ association and an individual ocean common carrier or an agreement between or among ocean common carriers in which the shipper makes a commitment to provide a certain minimum quantity or portion of its cargo or freight revenue over a fixed period, and the ocean common carrier or the agreement commits to a certain rate or rate schedule as well as defined service level, such as assured space, transit time, port rotation, etc. Authority to file or delegate the authority to file must be requested by a responsible official of the service contract carrier in writing by submitting the Form FMC-83, Service Contract Registration.

Key Information

Previous ICR	202107-1545-006

Federal Register Notices

Authorizing Statutes

Abstract

This document contains previously approved final regulations relating to joint returns, property exempt from levy, interest, penalties, offers in compromise, and the awarding of costs and certain fees. The regulations reflect changes to the law made by the Taxpayer Bill of Rights 2 and a conforming amendment made by the Personal Responsibility and Work Opportunity Reconciliation Act of 1996. The regulations affect taxpayers with respect to filing of returns, interest, penalties, court costs, and payment, deposit, and collection of taxes.

Key Information

Previous ICR	202302-2060-010

Federal Register Notices

Authorizing Statutes

Abstract

In this ICR, the EPA estimates additional one-time respondent burden of 2 labor hours in the first year following promulgation of the subject amendments to provide for becoming familiar with the amendments to NSPS subpart TTT and becoming familiar with the CDX and CEDRI systems associated with electronic submission of reports. These amendments will not impact the burden on respondents in later years because they do not impose additional reporting or recordkeeping requirements. The total estimated respondent burden as currently identified in the OMB Inventory of Approved Burdens is based on 10 respondents (a larger number than the three respondents counted in this ICR). The downward adjustment in the number of respondents for this ICR, based on the EPAs most recent information, is reflected in Attachment 1 to this ICR Supporting Statement.

Key Information

Previous ICR	202201-2060-015

Federal Register Notices

Authorizing Statutes

Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Flexible Polyurethane Foam Product (40 CFR Part 63, Subpart III) were proposed on December 27, 1996; promulgated on October 7, 1998; and amended on August 15, 2014 (79 FR 48073), and November 19, 2020 (85 FR 73854). These regulations apply to owners or operators of both new and existing facilities that engage in the manufacture of flexible polyurethane foam products which emit hazardous air pollutants (HAPs). This situation includes facilities making slabstock flexible polyurethane foam (slabstock foam), rebond flexible polyurethane foam (rebond foam), and/or molded flexible polyurethane foam (molded foam). This information is being collected to assure compliance with 40 CFR Part 63, Subpart III. In general, all NESHAP standards require initial notifications, performance tests, and periodic reports by the owners/operators of the affected facilities. Owners or operators of flexible polyurethane foam production facilities to which this rule is applicable must choose one of the compliance options described in these standards or reduce HAP emissions to below the compliance level. Specifically, the rule requirements for slabstock foam producers include an initial notification, notification of compliance status, semiannual reports, and annual compliance certifications. The rule requirements for molded and rebond foam producers include a notification of compliance status report and an annual compliance certification. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to NESHAP.

Key Information

Previous ICR	202203-1545-018

Federal Register Notices

Authorizing Statutes

Abstract

Information used by taxpayer to notify payer of expatriation so that proper tax treatment is applied by payer. The taxpayer is required to use this form to obtain any benefit accorded by the statute.

Key Information

Previous ICR	202201-1545-034

Federal Register Notices

Authorizing Statutes

Abstract

Section 475 was added by section 13223(a) of the Revenue Reconciliation Act of 1993, Pub. L. 103-66, 107 Stat.481, and is effective for all taxable years ending on or after December 31, 1993. The statutory requirements under 26 U.S.C. 475 are codified under 26 CFR Part 1, sections 1.475 et al. Information collection requirements under § 1.475(a)-4 sets forth an elective safe harbor that permits dealers in securities and dealers in commodities to elect to use the values of positions reported on certain financial statements as the fair market values of those positions for purposes of section 475 of the Internal Revenue Code (Code). This safe harbor is intended to reduce the compliance burden on taxpayers and to improve the administrability of the valuation requirement of section 475. The recordkeeping requirement under section 1.475(b)-4 are required to determine whether exemption from mark- to-market treatment is properly claimed, and will be used to make that determination upon audit of taxpayer's books and records. The information under section 1.475(c)-1(a)(3)(iii), is necessary to determine whether a consolidated group has elected to disregard inter-member transactions in determining a member's status as a dealer in securities.

Key Information

Previous ICR	202202-1545-005

Federal Register Notices

Authorizing Statutes

Abstract

This revenue procedure affects taxpayers who are maintaining a surety bond or a Treasury Direct Account (TDA) to satisfy the low-income housing tax credit recapture exception in § 42(j)(6) of the Internal Revenue Code, as in effect on or before July 30, 2008. This revenue procedure provides the procedures for taxpayers to follow when making the election under section 3004(i)(2)(B)(ii) of the Housing Assistance Tax Act of 2008 (Pub. L. 110–-289) to no longer maintain a surety bond or a TDA to avoid recapture.

Key Information

Previous ICR	202112-1545-009

Federal Register Notices

Authorizing Statutes

Abstract

Form 56 is used to notify the IRS of the creation or termination of a fiduciary relationship and provide qualification for the relationship. Form 56-F is used by the federal agency acting as a fiduciary to notify the IRS of the creation, termination, or change in status of a fiduciary relationship with a financial institution.

Key Information

Previous ICR	202201-2060-019

Federal Register Notices

Authorizing Statutes

Abstract

Previously, the EPA issued New Source Performance Standards (NSPS) (40 CFR Part 60, Subpart CCCC) and Emission Guidelines (40 CFR Part 60, Subpart DDDD) for Commercial and Industrial Solid Waste Incineration (CISWI) Units as promulgated on December 1, 2000 (65 FR 75338) and March 21, 2011 (76 FR 15769), and subsequently amended on: February 7, 2013 (78 FR 9195); June 23, 2016 (81 FR 41001); April 16, 2019 (84 FR 15846); and Oct. 7, 2020 (85 FR 63406) . The Emission Guidelines apply to any air quality program in either a state or a United States protectorate with one or more existing CISWI units. The guidelines can be thought of as model regulations that States use in developing State plans to implement the Emission Guidelines. If a state does not develop, adopt, and submit an approvable state plan, the Environmental Protection Agency (EPA) develops a Federal plan to implement the Emission Guidelines. The EPA previously promulgated a Federal Plan for CISWI units subject to the December 1, 2000 final rule on October 3, 2003 (68 FR 57518) under 40 CFR Part 62, Subpart III. On January 11, 2017, the EPA proposed amendments to the Federal plan requirements at 40 CFR Part 62, Subpart III to implement the regulations at 40 CFR Part 60, Subpart DDDD adopted on February 7, 2013, and as amended on June 23, 2016, and April 16, 2019. The EPA is subsequently finalizing the revised Federal Plan under new subpart 40 CFR Part 62, Subpart IIIa. Following the effective date of the final rule, the requirements of 40 CFR Part 62, Subpart III will no longer be in effect and all existing units subject to the Federal Plan must meet the requirements of 40 CFR Part 62, Subpart IIIa. These regulations will apply to existing CISWI units (units that commenced construction on or before June 4, 2010, or commenced modification or reconstruction after June 4, 2010 but no later than August 7, 2013) that are not regulated by an EPA approved and currently effective State or Tribal plan, or that are located in any state whose approved State or Tribal plan is only approved in part. Since EPA is finalizing the updated Federal plan at 40 CFR Part 62, Subpart IIIa, following the effective date of the final rule, all respondents previously subject to Subpart DDDD are now subject to either a State plan implementing 40 CFR Part 60, Subpart DDDD or are subject to the Federal plan under 40 CFR Part 62, Subpart IIIa, or if they have modified since August 7, 2013, they are subject to the NSPS at 40 CFR Part 60, Subpart CCCC. This information is thus being collected to assure compliance with 40 CFR Part 60, Subpart DDDD and 40 CFR Part 62, Subpart IIIa. The Federal Plan implements the Emissions Guidelines at 40 CFR Part 60, Subpart DDDD. In general, all Emissions Guidelines require initial notifications, performance tests, and periodic reports by the owners/operators of the affected facilities. They are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility, or any period during which the monitoring system is inoperative. These notifications, reports, and records are essential in determining compliance, and are required of all affected facilities subject to Emission Guidelines.

Key Information

Previous ICR	202502-0920-016

Federal Register Notices

Authorizing Statutes

Abstract

The National Healthcare Safety Network (NHSN) is a system designed to accumulate, exchange, and integrate relevant information and resources among private and public stakeholders to support local and national efforts to protect patients and promote healthcare safety. Specifically, the data is used to determine the magnitude of various healthcare-associated adverse events and trends in the rates of these events among patients and healthcare workers with similar risks. The data will be used to detect changes in the epidemiology of adverse events resulting from new and current medical therapies and changing risks. This Revision contains minor changes to a few forms and minor burden changes.

Key Information

Previous ICR	202107-2501-001

Federal Register Notices

Authorizing Statutes

Abstract

Form HUD Form 60002-A collects compliance information required by the rule called “Enhancing and Streamlining the Implementation of Section 3 Requirements for Creating Opportunities for Low- and Very-Low Income Persons and Eligible Businesses,” published at 24 CFR § 75. The Business Registry/Opportunity Portal have been combined into a single system to provide a more effective system for businesses to identify Section 3 business concern status and to post contracts and find workers.

Key Information

Previous ICR	202201-2060-017

Federal Register Notices

Authorizing Statutes

Abstract

The National Emission Standards for Hazardous Air Pollutants (NESHAP) for Ferroalloys Production: Ferromanganese and Silicomanganese (40 CFR Part 63, Subpart XXX) were promulgated on May 20, 1999; and amended on: March 22, 2001; June 23, 2003; April 20, 2006; June 30, 2015 (80 FR 37366); January 18, 2017 (82 FR 5408), and November 19, 2020 (85 FR 73902). These regulations apply to both new and existing ferroalloy production facilities that manufacture ferromanganese and silicomanganese, and that are either major sources of hazardous air pollutant (HAP) emissions or are co-located at major sources of HAPs. The following affected facilities at ferroalloy production plants are subject to this NESHAP rule: electric arc furnaces; casting operations; metal oxygen refining (MOR) processes; crushing and screening operations; and outdoor fugitive dust sources. New facilities include those that commenced construction or reconstruction after the date of proposal. The burden in this ICR reflects the burden associated with the recordkeeping and reporting requirements of the regulation for new and existing sources included in the June 30, 2015 Risk and Technology Review (RTR) final rule amendments and January 18, 2017 reconsideration notice. The burden associated with the 2015 final rule amendments and reconsideration notice is accounted for in EPA ICR No. 2448.02 (OMB Control No. 2060-0676). The 2020 amendment implemented the plain language reading of the “major source” and “area source” definitions of section 112 of the Clean Air Act (CAA) and provide that a major source can be reclassified to area source status at any time upon reducing its potential to emit (PTE) hazardous air pollutants (HAP) to below the major source thresholds and required this notification be submitted electronically. This information is being collected to assure compliance with 40 CFR Part 63, Subpart XXX.  In general, all NESHAP standards require initial notifications, performance tests, and periodic reports by the owners/operators of the affected facilities. They are also required to maintain records of the occurrence and duration of any startup, shutdown, or malfunction in the operation of an affected facility, or any period during which the monitoring system is inoperative. These notifications, reports, and records are essential in determining compliance and are required of all affected facilities subject to NESHAP.

Key Information

Previous ICR	202203-1545-007

Federal Register Notices

Authorizing Statutes

Abstract

The Internal Revenue Service offers free assistance with tax return preparation and tax counseling using specially trained volunteers. The Volunteer Income Tax Assistance (VITA) and Tax Counseling for the Elderly (TCE) programs assist seniors, eligible taxpayers, and members of underserved populations. The information provided on the forms in this collection will be used to approve grant and participation applications for the TCE and VITA programs. It will also be used to administer the programs, establish effective controls, send correspondence, recognize volunteers, and assist taxpayers with locating TCE and VITA sites.

Key Information

Previous ICR	202202-1545-015

Federal Register Notices

Authorizing Statutes

Abstract

Form 5498-ESA is used by trustees and issuers of Coverdell Education Savings accounts to report contributions and rollovers to these accounts and to the beneficiaries.

Key Information

Previous ICR	202201-1545-012

Federal Register Notices

Authorizing Statutes

Abstract

Form 8906, Distilled Spirits Credit, was developed to carry out the provisions of IRC section 5011(a). This section allows eligible wholesalers and persons subject to IRC section 5055 an income tax credit for the average cost of carrying excise tax on bottled distilled spirits. The form provides a means for the eligible taxpayer to compute the amount of credit.

Key Information

Previous ICR	202202-1545-010

Federal Register Notices

Authorizing Statutes

Abstract

Internal Revenue Code (IRC) section 6112 requires material advisors to maintain lists of advisees and other information with respect to reportable transactions and to make that information available to the Internal Revenue Service (IRS) upon written request. IRC section 6708 imposes a penalty upon material advisors for failing to make a list required by IRC section 6112 available to the IRS within 20 business days after the date of the written request. Treasury Decision (TD) 9764 contains final regulations relating to the penalty under IRC section 6708. The collection of information is in Treasury Regulations section 301.6708–1(c)(3)(ii), which requires a person requesting an extension of the 20-business-day period to provide the IRS, in writing, with specific information regarding the list and the circumstances that would warrant additional time.

Key Information

Previous ICR	202204-2060-012

Federal Register Notices

Authorizing Statutes

Abstract

The Emission Guidelines for Existing Other Solid Waste Incineration (OSWI) Units (40 CFR Part 60, Subpart FFFF) were proposed on December 9, 2004 (69 FR 71472), promulgated on December 16, 2005 (70 FR 74892), and amended on November 24, 2006 (71 FR 67806). Under the proposed rule, the Emission Guidelines apply to any air quality program in either a state or a United States protectorate with one or more existing OSWI units or air curtain incinerators that commenced construction either on or before December 9, 2004. The affected OSWI units include two additional sub-categories: very small municipal waste combustion (VSMWC) units that combust less than 35 tons per day (TPD) of waste and institutional waste incineration (IWI) units. This Subpart does not directly affect incineration unit owners and operators; however, they must comply with the states plan that was developed by the air quality program administrator to implement the emission guidelines. On August 31, 2020, the EPA published a proposed rule in the Federal Register for the OSWI NSPS and EG rules that addressed the requisite CAA section 129(a)(5) periodic review (85 FR 54178), as well as other proposed changes to the standards. The EPA is finalizing its CAA section 129(a)(5) review, including our determination that there are no developments in practices, processes, or control technologies that warrant revisions to the OSWI standards and requirements. The EPA is finalizing certain other revisions, including the addition of a subcategory of new VSMWC or IWI units that have a capacity to combust less than 10 TPD of waste that are constructed on or after August 30, 2020, including changes to applicability-related and definitional changes; changes to the startup, shutdown, and malfunction (SSM) provisions; changes to testing, monitoring, recordkeeping, and reporting requirements; and other miscellaneous technical and editorial changes. The EPA is also finalizing electronic reporting requirements for submittal of certain reports and performance test results. This ICR includes the burden associated with the existing rule requirements and the incremental burden associated with the final rule. This information is being collected to assure compliance with 40 CFR Part 60, Subpart FFFF.

Key Information

Previous ICR	202201-1545-019

Federal Register Notices

Authorizing Statutes

Abstract

The Internal Revenue Service (IRS) designed the Gaming Industry Tip Compliance Agreement (GITCA) to promote compliance by gaming industry employers and employees with the provisions of the Internal Revenue Code (IRC) relating to tip income and to reduce disputes under IRC Section 3121(q). Under the GITCA Program, a gaming industry employer and the Internal Revenue Service (IRS) work together to reach a GITCA that establishes minimum tip rates for participating tipped employees in specified occupational categories, prescribes a threshold level of participation by the employer's employees, and reduces compliance burdens for the employer and enforcement burdens for the IRS.

Key Information

Previous ICR	202112-1545-005

Federal Register Notices

Authorizing Statutes

Abstract

TD 9304 provides guidance to taxpayers regarding the apportionment of tax benefit items under section 1561(a) amongst the component members of a controlled group of corporations. TD 9329 contains final regulations that simplify, clarify, or eliminate reporting burdens and also eliminate regulatory impediments to the electronic filing of certain statements that taxpayers are required to include on or with their Federal income tax returns. TD 9451 provides guidance to taxpayers for determining which corporations are included in a controlled group of corporations. TD 9759 provides guidance for preventing the importation of loss when a corporation that is subject to U.S. income tax acquires loss property tax-free in certain transactions and the loss in the acquired property accrued outside the U.S. tax system by requiring the bases of the assets received to be equal to value.

Key Information

Previous ICR	202305-1545-024

Federal Register Notices

Authorizing Statutes

Abstract

Rev. Proc. 2025-1 contains revised procedures for letter rulings and information letters issued by the Associate Chief Counsel (Corporate), Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes), Associate Chief Counsel (Financial Institutions and Products), Associate Chief Counsel (Income Tax and Accounting), Associate Chief Counsel (International), Associate Chief Counsel (Passthroughs and Special Industries), and Associate Chief Counsel (Procedure and Administration). This procedure also contains procedures for determination letters issued by the Large Business and International Division, Small Business/Self Employed Division, Wage and Investment Division, and Tax Exempt and Government Entities Division. Rev. Proc. 2024-1 is superseded. Rev. Proc. 2023-26 describes a program that provides an opportunity for fast-track processing of certain requests for letter rulings solely or primarily under the jurisdiction of the Associate Chief Counsel (Corporate). This new program replaces the pilot program established by Rev. Proc. 2022-10, 2022-6 I.R.B. 473.

Key Information

Previous ICR	202201-1545-022

Federal Register Notices

Authorizing Statutes

Abstract

The regulations require a partnership to notify the partner of the satisfaction of certain liabilities described in the regulation, providing the partner with specific information regarding the partnership’s assumption of liability. The partner must attach this notification to their tax return for the year in which the loss is being claimed.

Key Information

Previous ICR	202201-1545-032

Federal Register Notices

Authorizing Statutes

Abstract

The purpose of section 482 is to ensure that taxpayers clearly reflect income attributable to controlled transactions and to prevent the avoidance of taxes with respect to such transactions. Revenue Procedure 2015-41 provides guidance on the process of requesting and obtaining advance pricing agreements from the Advance Pricing and Mutual Agreement program (“APMA”). This revenue procedure also provides guidance on administration of an executed advance pricing agreement (APA).