SECTION 1. PURPOSE

This revenue procedure modifies Rev. Proc. 80–18, 1980–1 C.B. 623, by setting forth new rules and procedures for applying Articles 10(2)(a) and 23(1)(b) and (c) of the United States-United Kingdom Income Tax Convention, signed on December 31, 1975, as amended by an Exchange of Notes, signed on April 13, 1976, and Protocols, signed on August 26, 1976, March 31, 1977, and March 15, 1979 (the “Convention”), 1980–1 C.B. 394, with respect to dividends paid by corporations resident in the United Kingdom after April 5, 1999 to U.S. shareholders. Revised rules and procedures are necessary because the United Kingdom repealed its advance corporation tax (“ACT”) and reduced the shareholder tax credit with respect to dividends effective April 6, 1999.