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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.
A complete listing of the information that must be included with the request can be found in Revenue Procedure 2015-40 available at www.irs.gov/irb/2015-35_IRB/ar10.html.
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
Washington, DC 20224
SE:LB:IN:ADCI:TAIT:M4-365
(Attention: TAIT)