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taxmap/pubs/p597-006.htm#en_us_publink1000104537

Competent Authority Assistance(p3)


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Under Article XXVI, a U.S. citizen or resident may request assistance from the U.S. competent authority when the actions of Canada, the United States, or both, potentially result in double taxation or taxation contrary to the treaty. The U.S. competent authority may then consult with the Canadian competent authority to determine if the double taxation or denial of treaty benefits in question can be avoided.
If the competent authorities are not able to reach agreement in a case, binding arbitration proceedings may apply.
It is important that your request for competent authority assistance be made as soon as you have been notified by either Canada or the United States of proposed adjustments that would result in denial of treaty benefits or in double taxation. This is so that implementation of any agreement reached by the competent authorities is not barred by administrative, legal, or procedural barriers. For information that you should include with your request for competent authority assistance, see Revenue Procedure 2006-54, 2006-49 IRB 1035, available at www.irs.gov/irb/2006-49_IRB/ar13.html. The request should be addressed to:

 
Deputy Commissioner (International) 
Large and Mid-Size Business Division 
Attn: Office of Tax Treaty  
Internal Revenue Service 
1111 Constitution Ave., NW 
Routing: MA3-322A 
Washington, D.C. 20024


In addition to a timely request for assistance, you should take the following measures: