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of 8821/2848’s›Exception:

Requesting Competent Authority Assistance in Determining Eligibility for Treaty Benefits

Internal Revenue Manual Part 21. Customer Account Services · 2026-10-03 edition · updated 2026-10-04 · United States

Competent Authority provides help to any applicant that is authorized by a U.S. treaty to seek Competent Authority help.

Competent Authority also provides help to any applicant that has been declined certification but believes that they are entitled to treaty benefits under a specific U.S. treaty article, provided:

The request for such help is made following Rev. Proc. 2015-40 PDF.

It can be established that the issue requires consultation with the foreign competent authority to ensure consistent treatment by the United States and the applicable treaty country.

The Competent Authority does not make unilateral determinations with respect to residency. Therefore, all requests for residency determination are made by mutual/bilateral agreement between the two Competent Authorities.

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▸Contents — Internal Revenue Manual Part 21. Customer Account Services

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