Note:
Internal Revenue Manual Part 21. Customer Account Services · 2026-10-03 edition · updated 2026-10-04 · United States
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If the applicant is a resident of a foreign country for the year certification is requested, the applicant is not entitled to treaty benefits, unless approved by mutual agreement between the competent authorities.
Issue letter 3425, which explains that, according to our records, the applicant claimed a foreign tax home. Accordingly, it has been determined that the applicant is not entitled to treaty benefits and therefore, a U.S. residency certification cannot be provided.
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