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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

All correspondence is auto closed 60 days after the letter issue date or status date, whichever is later.

Any subsidiary corporation that has had its application declined, but believes it is entitled to U.S. Residency Certification, must submit a copy of its completed Form 8802, attach a detailed explanation and/or regulation or Code section, including documentary evidence, as to why it believes it is entitled to certification.

Place the case in status 702.

Notate in Remarks Section that the case is being forwarded to Planning and Analysis.

Forward all applications and attachments to Planning and Analysis.

Any subsidiary corporation that has had its application declined or certification rejected, but believes it is entitled to treaty benefits under a specific treaty article, must follow Rev. Proc. 2015-40 to request Competent Authority help.

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

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