SECTION 1. PURPOSE

This revenue procedure sets forth the procedures concerning requests to the U.S. competent authority for assistance in resolving cases under Article XIII(8) of the Convention Between the United States of America and Canada with respect to Taxes on Income and Capital, dated September 26, 1980, as amended by the Protocols dated June 14, 1983, March 28, 1984, March 17, 1995, and July 29, 1997 (“the Treaty”), 1986–2 C.B. 258. Article XIII(8) of the Treaty permits taxpayers to request the competent authority to defer the recognition of profit, gain, or income with respect to property alienated in the course of a corporate or other organization, reorganization, or similar transaction. See also Rev. Proc. 96–13, 1996– 1 C.B. 616, for an updated discussion of the general procedures concerning requests by taxpayers for assistance of the U.S. competent authority under the provisions of an income, estate, or gift tax treaty to which the United States is a party.