Valuation Research Corporation (VRC), a leading global provider of independent valuation support and advisory services, announced that Tom K. Gottfried, Esq., Managing Director-National Tax Valuation, was tapped by the American Bar Association’s Tax Section to join a select group of professionals that drafted suggestions for the IRS as it seeks to update its Revenue Procedures concerning Advanced Pricing Agreements and Mutual Agreement Procedures.

APAs are advance pricing arrangements between a taxable entity and a single or multiple tax authorities on the pricing methodology for certain cross-border transactions including tax valuation methodologies associated with certain fixed asset, intangible asset, or business transfers.

The group also recommended changes to mutual agreement procedures (MAP), which is a dispute resolution mechanism to avoid potential double taxation among treaty partners arising from various cross-border tax disputes such as tax valuation of certain fixed asset, intangible asset, or business transfers.

“It was a pleasure working with such a distinguished group of professionals from the legal, accounting and valuation spheres to share our vision for an approach that is more efficient and, at the same time, more robust,” said Gottfried.

Among other things, the group’s June 20 letter to the IRS suggested:

• Reduction and rationalization of the information requested by the IRS;
• Alignment with OECD best practices; and
• Allowing an APA submission to satisfy other Treasury reporting requirements.

The ABA Tax Section letter to the IRS can be found here.