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Announcement 2006-22 April 17, 2006

APPENDIX B Model APA -
Based on Revenue Procedure 2006-9

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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Internal Revenue Bulletin 2006-16

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