Which of the Following Best Describes an Advanced Pricing Agreement

Which of the following best describes an Advanced Pricing Agreement (APA) ?

A) An agreement between a corporation and a foreign subsidiary as to what method, cost or market-based, will be used to set a transfer price for products.
B) A binding agreement between a foreign government's taxing authority, the IRS and a U.S. based corporation to help avoid disputes related to transfer pricing.
C) An agreement under IRS code Section 482 that requires a company to utilize market based transfer prices and to document them for tax return purposes.
D) A binding agreement between the IRS and a corporation to help avoid disputes related to transfer pricing.