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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

Only Canadian and Mexican corporations are eligible to be treated as domestic corporations under IRC 1504(d).

Corporations neither incorporated in the United States, nor treated as a domestic corporation under IRC 269B, IRC 953(d), IRC 1504(d), or IRC 7874(b) but believe entitlement to U.S. Residency Certification, must seek competent authority help using Rev. Proc. 2015-40 to request certification. In addition, the applicant must:

Complete Form 8802.

Attach a detailed explanation, as to their entitlement.

Submit all documentary evidence.

U.S. corporations must file one of the corporate forms within the 1120 series to qualify for certification. The filing requirements on the Form 1120 filer’s entity module are shown as 1120-01.

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

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