Publication 54 - Tax Guide For U.s. Citizens And Resident Aliens Abroad - 2006 Page 35
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44•
Contesting an adjustment or seeking an
the request with the IRS office where your case
You can get complete information about
appropriate correlative adjustment with re-
is pending. If the request is filed after the matter
treaty provisions from the taxing authority in the
spect to the U.S. or treaty country tax.
has been designated for litigation or while a suit
country from which you receive income or from
contesting your relevant tax liability is pending in
the treaty itself. You can obtain the text of most
Taxpayers can consult with the U.S. competent
a United States court, a copy of the request also
U.S. treaties at You can also re-
authority to determine whether they need to take
must be filed with the Office of Associate Chief
quest the text of treaties from the Department of
protective steps and when any required steps
Counsel (International), lnternal Revenue Serv-
Treasury at the following address.
need to be taken.
ice, 1111 Constitution Avenue NW, Washington,
The request should contain all essential items
DC 20224, with a separate statement attached
Department of Treasury
of information, including the following items.
identifying the court where the suit is pending
Office of Public Correspondence
and the docket number of the action.
•
A reference to the treaty and the treaty
Rm. 3419
Additional details on the procedures for re-
provisions on which the request is based.
1500 Pennsylvania Avenue, NW
questing competent authority assistance are in-
Washington, DC 20220
•
The years and amounts involved in both
cluded in Revenue Procedure 2006-54.
U.S. dollars and foreign currency.
If you have questions about a treaty and you
More information on treaties. Publication
•
A brief description of the issues for which
are in the United States, Puerto Rico, or the
901 contains an explanation of treaty provisions
competent authority assistance is re-
U.S. Virgin Islands, you can call the IRS at
that apply to amounts received by teachers,
quested.
1-800-829-1040. From anywhere in the world,
students, workers, and government employees
you can send your questions to:
and pensioners who are alien nonresidents or
A complete listing of the information that must be
residents of the United States. Since treaty pro-
included with the request can be found in Reve-
visions generally are reciprocal, you can usually
nue Procedure 2006-54, 2006-49 I.R.B. 1035,
Internal Revenue Service
substitute “United States” for the name of the
available at
International Section
treaty country whenever it appears, and vice
pdf.
P.O. Box 920
versa when “U.S.” appears in the treaty exemp-
Bensalem, PA 19020-8518
tion discussions in Publication 901.
Your request for competent authority
Publication 597 contains an explanation of a
consideration should be addressed to:
number of frequently-used provisions of the
United States – Canada income tax treaty.
Deputy Commissioner (International)
Large and Mid-Size Business Division
Attn: Office of Tax Treaty
Obtaining Copies
Internal Revenue Service
1111 Constitution Avenue, NW
of Tax Treaties
Routing MA3-322A
Washington, DC 20224
Table 6-1 lists those countries with which the
Additional filing. In the case of U.S.- initi-
United States has income tax treaties. This table
ated adjustments, you also must file a copy of
is updated through September 30, 2006.
Chapter 6 Tax Treaty Benefits
Page 35
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