bulletin Internal Revenue›Article XIII(8) of the Treaty should follow the procedures in Rev. Proc. 96–13.
SEC. 6. ACTION BY THE U.S.
Internal Revenue Bulletin 1998-8 · 2026-10-03 edition · updated 2026-10-04 · United States
COMPETENT AUTHORITY
.01 Notification of Taxpayer . Upon receiving a request for relief pursuant to this revenue procedure, the U.S. competent authority will consider whether the facts provide a basis for assistance.
.02 Extending Period of Limitations for Assessment. If the U.S. competent authority accepts a request for assistance, the taxpayer may be requested to execute a consent extending the period of limitations for assessment of tax for the taxable periods in issue. Failure to comply with the provisions of this subsection can result in denial of assistance by the U.S. competent authority with respect to the request.
.03 Determination regarding relief. The decision whether to grant relief will be made based upon all of the facts and circumstances.
.04 No Review of Denial of Request for Assistance. The U.S. competent authority’s denial of a taxpayer’s request for assistance or dismissal of a matter previously accepted for consideration pursuant to this revenue procedure is final and not subject to administrative review.
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