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IRS Releases Quarterly APA Report

OCT. 5, 2007

IRS Releases Quarterly APA Report

DATED OCT. 5, 2007
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DEPARTMENT OF THE TREASURY

 

INTERNAL REVENUE SERVICE

 

WASHINGTON, D.C. 20224

 

 

MEMORANDUM FOR:

 

Steven A. Musher

 

Associate Chief Counsel (International)

 

 

FROM:

 

Matthew W. Frank, APA Program Director

 

 

DATE:

 

October 5, 2007

 

 

SUBJECT:

 

APA Quarterly Report for FY 2007, Fourth Quarter Ending 09/30/07

 

 

The following are the APA Program's results for the fourth quarter of FY 2007 ("Q4").

APAs Completed

The APA Program completed 25 APA matters in Q4, consisting of 17 bilateral APAs, 3 unilateral APAs, and 5 amendments.

Negotiating Position Papers

The APA Program completed 16 bilateral negotiating position papers in Q4.

Annual Reports

The APA Program completed its review of and closed 55 annual reports in Q4,

New Matters

The APA Program received 34 new APA matters in Q4, consisting of 23 bilateral matters and 11 unilateral APA matters.

APA Inventory

The APA Program has an ending inventory of 251 open matters.1 This consists of 210 bilateral and 41 unilateral matters.2

Attached for your information is the APA issuance report and open inventory reports as of September 30, 2007, Please contact me at (202) 435-5222 if any additional information is required.

Respectfully submitted,

 

 

Matthew W. Frank

 

APA Program Director

 

Attachments

 

 

cc:

 

LMSB Commissioner

 

Director, International National

 

Director of Appeals

 

LMSB Division Counsel

 

FOOTNOTES

 

 

1 This equals beginning Q4 inventory of 242 matters, plus 34 receipts, less 25 closures {242 + 34 - 25 = 251}.

2 The 251 open matters include 29 pending dollar filings (18 bilateral and 11 unilateral). Thus

  • The APA Program has an inventory of 222 active cases, i.e., 251 open matters less 29 pending dollar filings.

  • The 222 active cases consist of 192 bilateral cases (210 total bilateral matters less 18 pending bilateral dollar filings) and 30 unilateral cases (41 total unilateral matters less 11 pending unilateral dollar filings).

  • The APA Program has forwarded 115 of the 192 active bilateral matters to Competent Authority. Thus, the APA Program has a current working inventory of 107 cases, consisting of 77 bilateral cases (192 active bilateral cases less 115 forwarded to Competent Authority) and 30 active unilateral cases.

END OF FOOTNOTES
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