SEC. 3. PROCEDURES FOR

OBTAINING REV. PROC. 65–17 RELIEF IN TREATY CASES

If a taxpayer intends to request competent authority assistance pursuant to Rev. Proc. 96–13, page 31, this Bulletin, to resolve a double taxation matter in a treaty case, the taxpayer should request relief under Rev. Proc. 65–17 in conjunction with its request for competent authority assistance under the provisions of Rev. Proc. 96–13, sec. 4 and sec. 10. In addition, where a request for relief under Rev. Proc. 65– 17 is already pending before the Service at the time a request for competent authority assistance is made, the taxpayer must forward a copy of the pending Rev. Proc. 6–17 request to the U.S. competent authority. The U.S. competent authority will consider relief under Rev. Proc. 65–17 in conjunction with consideration of the competent authority matter. If a taxpayer does not intend to request competent authority assistance in a treaty case, the taxpayer must follow the procedures under Rev. Proc. 65–17 to request relief provided thereunder; however, the closing agreement required in that revenue procedure cannot be entered into except with the concurrence of the Assistant Commissioner (International).