An APA procedure shall only be implemented if the request is admissible and reasoned. 2. Allow the taxable person to conclude a unilateral ABS if, after examination of a draft APA, the Russian and foreign tax authorities do not reach a mutual agreement. Bilateral and multilateral AAAs are generally bilateral or multilateral, i.e. they also include agreements between the taxable person and one or more foreign tax administrations under the supervision of the cartel procedure (POPs) established in income tax treaties.  The taxable person benefits from such agreements, as it is certain that the income related to the covered transactions is not subject to double taxation by the IRS and the competent foreign tax authorities. Irs policy is to “encourage” taxpayers to seek bilateral or multilateral APAs where there are provisions of the relevant authorities. . . .