TEI Consults on Draft Information Circular for APAs.

At the invitation of the Canadian government, members of TEI's Canadian Income Tax Committee met with representatives of Canada Customs and Revenue Agency (CCRA) in Toronto, Ontario, on July 5, 2000. The purpose of the meeting was to engage in private consultations on a draft information circular relating to Advance Pricing Arrangements (APAs). Upon release, the circular will replace IC 94-4.

Following the meeting, TEI provided written comments on the policy and administrative issues raised by the draft information circular. The comments, which took the form of a 14-page letter from TEI President Betty M. Wilson to Gary Zed, Director of the Transfer Pricing and Competent Authority Division for CCRA, were submitted on September 15, 2000.

In his position with CCRA, Mr. Zed serves as the Canadian government's representative in competent authority negotiations. Mr. Zed, along with Carol A. Dunahoo, the IRS's Director of International (and U.S. competent authority representative), will jointly address TEI on Monday, October 23rd during the Institute's 55th Annual Conference in San Diego. The Canadian government anticipates releasing the revised APA circular sometime this year, but it is unclear whether the document will be released in time for TEI's Conference.

In keeping with customary practice, CCRA has not released the draft APA circular for public comment. Moreover, as a condition for participating in private consultations, TEI agreed to preserve the confidentiality of the draft circular and the discussions. As a result, the written comments...