Taxation of global trading operations: Use of advance pricing agreements and profit-split methodology

Advanced in communications and computer technologies, innovations in financial products, and changes in the regulatory scheme have empowered the world's financial institutions to conduct their trading activities around the globe, 24 hours a day. However, tax laws and regulations have not kept pace with the globalization of trading practices. Traditional US tax regimes based on geographic identifications have become inadequate to tax these operations. Recently, the Service has turned to the Advance Pricing Agreements (APA) procedure to address the taxation of global trading.