As has been widely reported, Michael Danilack, assistant commissioner, International resigned in early July, following the resignation of Richard McAlonan, director of the Advance Pricing Mutual Agreement Program, and followed by the resignation of Sam Maruca, director of Transfer Pricing Operations within the IRS.
All three individuals joined the IRS from the private sector, and were involved in a shift of the direction of transfer pricing administration at the IRS over the past three years.
At the IRS, these officials oversaw the merger of the Advance Pricing Agreement Program with the Mutual Agreement Program. That merger moved the APA Program, then situated in the Office of Associate Chief Counsel (International), over to the Commissioner’s side of the IRS and aligned it under Maruca’s direction. Read a list of questions and answers provided by the IRS in a February 2014 release about the programs’ merger.
Following the programs’ merger, there was significant hiring within the Advance Pricing Mutual Agreement Program (APMA), and case closing statistics reveal an increase from 43 in 2011, to 140 in 2012 and a further increase to 145 in 2013.
Hareesh Dhwale, APMA deputy director, will be serving as acting director of the APMA Program.
Doug O’Donnell, formerly assistant deputy commissioner (International) for LB&I, will serve as the acting deputy commissioner (International).
Contact a tax professional with KPMG's Global Transfer Pricing Services.