SEC. 2. BACKGROUND

Rev. Rul. 82–80, 1982–1 C.B. 89, and Rev. Proc. 65–17, 1965–1 C.B. 833, as amplified, amended, clarified and modified by Rev. Proc. 65–31, 1965–2 C.B. 1024, Rev. Proc. 65–17 Amendment I, 1966–2 C.B. 1211, Rev. Proc. 65–17 Amendment II, 1974–1 C.B. 411, Rev. Proc. 70–23, 1970–2 C.B. 505, Rev. Proc. 71–35, 1971–2 C.B. 573, Rev. Proc. 72–48, 1972–2 C.B. 829, Rev. Proc. 72–53, 1972–2 C.B. 833, and Rev. Proc. 91–24, 1991– 1 C.B. 542, (hereinafter referred to as ‘‘Rev. Proc. 65–17’’) provide for the tax-free repatriation of certain amounts following an allocation of income between related U.S. and foreign corporations under section 482 of the Code. Generally, in order to obtain the treatment provided by Rev. Proc. 65– 17, the taxpayer must file a written statement requesting such relief with the appropriate District Director. However, in situations involving a country with which the United States has an income tax convention in force which contains a mutual agreement procedure article (‘‘treaty cases’’), Rev. Proc. 91–

24 provides that the relief provided under Rev. Proc. 65–17 is available only in conjunction with a request for assistance from the U.S. competent authority. This revenue procedure supersedes Rev. Proc. 91–24.