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Some companies may determine that an APA is not necessary.
Most small and medium-size businesses with controlled foreign affiliates will want to at least take the preliminary steps to consider obtaining an APA, even if they do the work entirely in-house and ultimately determine not to advance the APA to completion.
According to a recent study by the Spectrem Group, the number of affluent APA investors increased more than five-fold between 2000 and 2002.
In contrast to the Fortune 500, over 30% of the companies in the NASDAQ 100, comprised of many of the country's most innovative companies, have at least one APA on their boards.
21) In contrast, the IRS has set a goal of concluding unilateral APAs within 12 months, and also agreeing on the U.
The machine operator can use a touchpad control panel to teach the APAS assistant work plans graphical step-by-step representations of the task it is to perform within a very short space of time.
Of particular note, the PATA Guidance targets a two-year start-to-finish time frame for bilateral APAs, which would represent a dramatic improvement.
Second, the initial term of the SBT APA will be three years (with a potential to renew for a longer term).
In addition, the costs and potential hassle involved with APAs may be considerable.
The proposed changes in the revised APA revenue procedure (New APA Procedure) include additional details regarding the "pre-filing" process, a detailed appendix regarding the materials and information that a taxpayer must include in an APA request, and rules for when the IRS may cancel or revoke a completed APA.
From Fig-16 to Fig-24, we analyze APA S-box and [S.
APA Publication Manual: Tips on Usage: http://ocls.