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IRS's Advance Pricing and Mutual Agreement Program Rebounds in 2023: What Is APMA's Long Game? | Alston & Bird

APMA set a record for executed advance pricing agreements (APAs), but high processing times and a hefty pending APA inventory continued to challenge APMA in 2023. Our Federal &. ....

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YA Global, the Existence of a U.S. Trade or Business, and the Search for Greater Clarity | Alston & Bird

Our Federal & International Tax Group examines a long-awaited Tax Court ruling that helps clarify when a non-U.S. company engages in a “U.S. trade or business.” ....

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