Note:
Internal Revenue Manual Part 21. Customer Account Services · 2026-10-03 edition · updated 2026-10-04 · United States
See IRM 21.8.4.4.13.5, Certification Issues With a Foreign Country
, for more information.
Refer certification recipients that are entitled to a reduction in the foreign statutory rate of tax, or an exemption from foreign tax for certain types of income according to U.S. treaties but are denied, to Rev. Proc. 2015-40.
Rev. Proc. 2015-40 can be found on the internet at Rev Proc 2015-40 PDF. It explains the procedures for requesting U.S. Competent Authority assistance.
The U.S. Competent Authority only addresses matters covered in the applicable U.S. income tax treaty.
Requests for U.S. Competent Authority assistance must be mailed to:United States Competent Authority (Attention: TAIT)Internal Revenue Service SE:LB:TTPO:APMA:TAITMail Stop 76091111 Constitution Ave. N.W., Washington, DC 20224
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