United States

U.S.–Canada MAP and APAs: An In-depth Look

May 04, 2017
From the KPMG TaxWatch

Resolving a double-taxation issue through the mutual agreement procedure (MAP) in the U.S.–Canada tax treaty? Or considering entering into an advance pricing agreement (APA) between the United States and Canada?

You'll want to read this pair of articles in which the authors lay out the history and current state of MAP and APAs between these countries.


APAs in the U.S. and Canada: Guidance and Practice Since 1990
May 4, 2017 | Tax Management Transfer Pricing Report

The authors examine the history of APAs in the United States and Canada from the first test case in 1990 to the present and provide a series of recommendations for taxpayers to consider when applying for a U.S.-Canada bilateral APA.

The authors examine practice in the U.S. and Canadian government offices tasked with resolving double-tax disputes, detailing in particular how the process has evolved since the 1990s. Recommendations to consider for a successful and timely APA request involving the United States and Canada are provided.


  • Sean Foley, Tax Principal and Head of Global Transfer Pricing Services (GTPS), KPMG LLP (U.S.)
  • Francois Vincent, Tax Principal and GTPS Leader in Chicago, KPMG LLP (U.S.)
  • Steve Wrappe, Tax Principal and GTPS Deputy Leader of the Global Transfer Pricing Dispute Resolution Network, KPMG LLP (U.S.)
  • Cameron Taheri, GTPS Senior Manager, KPMG LLP (U.S.)
  • David Francescucci, Tax Partner and National Leader of GTPS in Canada, KPMG Law LLP (Canada)
  • Anne Curry, GTPS Senior Manager, KPMG LLP (U.S.)