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of 8821/2848’s

Note:

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

Most U.S. treaties have similar tiebreaker provisions for individuals. Residency must be determined according to the provisions of the U.S. tax treaty applicable to the specific dual resident individual.

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

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