SECTION 14. FEES

.01 Requests to Which a User Fee Does Not Apply . Except as provided in section 14.02 of this revenue procedure, no user fees are required with respect to a request for U.S. competent authority assistance pursuant to this revenue procedure.

.02 Requests to Which a User Fee Ap- plies . In general, a $15,000 user fee applies to all requests for determinations on limitation on benefits, as described in section 3.08 of this revenue procedure. The fee will apply regardless of whether the request is for: (a) an initial determination; (b) a renewal of a previously issued determination; or (c) a supplemental determination required, for example, if there is a material change in fact or if the taxpayer seeks benefits with respect to a different type of income or requests a lower rate of withholding tax on dividends. If a request is submitted that requires the U.S. competent authority to make a discretionary determination for more than one entity, a separate user fee will be charged for each entity.

.03 Acceptance of Requests . A user fee will not be charged until the U.S. competent authority has formally accepted the re

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the administration of any internal revenue law. Generally, tax returns and tax return information are confidential, as required by section 6103 of the Code.