Internal Revenue Bulletin: 2006-16 |
April 17, 2006 |
| CRITICAL ASSUMPTIONS | |
| This APA’s critical assumptions are: | |
| 1. The business activities, functions performed, risks assumed, assets employed, and financial and tax accounting methods and classifications [and methods of estimation] of Taxpayer in relation to the Covered Transactions will remain materially the same as described or used in Taxpayer’s APA Request. A mere change in business results will not be a material change. | |
| [Insert additional provisions as needed.] |
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