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IRS.gov Website
Publication 54
taxmap/pubs/p54-024.htm#en_us_publink100047611

Competent
Authority Assistance(p28)

rule
If you are a U.S. citizen or resident alien, you can request assistance from the U.S. competent authority if you think that the actions of the United States, a treaty country, or both, cause or will cause a tax situation not intended by the treaty between the two countries. You should read any treaty articles, including the mutual agreement procedure article, that apply in your situation.
The U.S. competent authority cannot consider requests involving countries with which the United States does not have a tax treaty.
taxmap/pubs/p54-024.htm#en_us_publink100047612

Effect of request for assistance. (p28)

rule
If your request provides a basis for competent authority assistance, the U.S. competent authority generally will consult with the treaty country competent authority on how to resolve the situation.
taxmap/pubs/p54-024.htm#en_us_publink100047613

How to make your request. (p28)

rule
It is important that you make your request for competent authority consideration as soon as either of the following occurs.
In addition to making a request for assistance, you should take steps so that any agreement reached by the competent authorities is not barred by administrative, legal, or procedural barriers. Some of the steps you should consider taking include the following.Taxpayers can consult with the U.S. competent authority to determine whether they need to take protective steps and when any required steps need to be taken.
The request should contain all essential items of information, including the following items.
A complete listing of the information that must be included with the request can be found in Revenue Procedure 2006-54, or its successor. Revenue Procedure 2006-54 is available at www.irs.gov/irb/2006-49_IRB/ar13.html.
Also, see Notice 2013-78, which provides proposed updates to the procedures for requesting U.S. competent authority assistance under tax treaties. As noted, Revenue Procedure 2006-54 will be superseded by a revenue procedure to be published in the future.
Due date
Your request for competent authority consideration should be addressed to:


Deputy Commissioner (International)
Large Business and International Division
Internal Revenue Service
1111 Constitution Avenue, NW
Routing M4-365
Washington, DC 20224
Attn: TAIT


taxmap/pubs/p54-024.htm#en_us_publink100047615
Additional filing.(p29)
In the case of U.S.- initiated adjustments, you also must file a copy of the request with the IRS office where your case is pending. If the request is filed after the matter has been designated for litigation or while a suit contesting your relevant tax liability is pending in a United States court, a copy of the request, with a separate statement attached identifying the court where the suit is pending and the docket number of the action, also must be filed with the:

Office of Associate Chief Counsel (International)
Internal Revenue Service
1111 Constitution Avenue, NW
Washington, DC 20224


Additional details on the procedures for requesting competent authority assistance are included in Revenue Procedure 2006-54, or its successor.