A Priority Guidance Plan for 2014-2015 was recently released by the U.S. Treasury and Internal Revenue Service that will be given special attention through this coming year (12 months that began July 2014).

What does the plan include?

The plan is divided into the major areas of U.S. taxation and addresses many topics including:

• Transfer pricing- There are many projects intended to address treatment and allocation of risk, the Advance Pricing Agreement (APA) program and the Advance Pricing and Mutual Agreement (APMA) program.
• Foreign Tax Credits (FTCs)- There are a number of other projects working to address issues like overall foreign losses and foreign tax redeterminations.

Stay tuned for periodic updates from the Treasury and IRS. Copies of the plan are available on the IRS website. For more information please read our article “U.S. Treasury and IRS identify 2014-2015 International Tax Priorities”