Publication 54 - Tax Guide For U.s. Citizens And Resident Aliens Abord - 2011 Page 35

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•
Avoiding the lapse or termination of your
Your request for competent authority
Obtaining Copies
right to appeal any tax determination.
consideration should be addressed to:
•
of Tax Treaties
Complying with all applicable procedures
Deputy Commissioner (International)
for invoking competent authority consider-
Large Business and International Division
ation.
Attn: Office of Tax Treaty
Table 6-1 lists those countries with which the
•
Internal Revenue Service
Contesting an adjustment or seeking an
United States has income tax treaties. This table
1111 Constitution Avenue, NW
appropriate correlative adjustment with re-
is updated through October 31, 2011.
Routing MA3-322A
spect to the U.S. or treaty country tax.
You can get complete information about
Washington, DC 20224
treaty provisions from the taxing authority in the
Taxpayers can consult with the U.S. competent
country from which you receive income or from
authority to determine whether they need to take
Additional filing. In the case of U.S.- initi-
the treaty itself. You can obtain the text of most
protective steps and when any required steps
ated adjustments, you also must file a copy of
U.S. treaties at IRS.gov. You also can request
need to be taken.
the request with the IRS office where your case
the text of treaties from the Department of Trea-
is pending. If the request is filed after the matter
The request should contain all essential items
sury at the following address.
has been designated for litigation or while a suit
of information, including the following items.
Department of Treasury
contesting your relevant tax liability is pending in
•
Executive Secretariat
A reference to the treaty and the treaty
a United States court, a copy of the request, with
Rm. 3413
provisions on which the request is based.
a separate statement attached identifying the
1500 Pennsylvania Avenue, NW
court where the suit is pending and the docket
•
The years and amounts involved in both
Washington, DC 20220
number of the action, also must be filed with the:
U.S. dollars and foreign currency.
Office of Associate Chief Counsel
•
If you have questions about a treaty and you
A brief description of the issues for which
(International)
are in the United States, Puerto Rico, or the
competent authority assistance is re-
Internal Revenue Service
U.S. Virgin Islands, you can call the IRS at
quested.
1111 Constitution Avenue, NW
1-800-829-1040.
A complete listing of the information that must be
Washington, DC 20224
included with the request can be found in Reve-
nue Procedure 2006-54, 2006-49 I.R.B. 1035,
Additional details on the procedures for re-
available at
questing competent authority assistance are in-
html.
cluded in Revenue Procedure 2006-54.
Table 6 –1. List of Tax Treaties (Updated through October 31, 2011)
Applicable Treasury
Official Text
General
Explanations
Country
Symbol
Effective Date
Citation
or Treasury Decision (T.D.)
1
Australia
TIAS 10773
Dec. 1, 1983
1986-2 C.B. 220
1986-2 C.B. 246
Protocol
TIAS
Jan. 1, 2004
Austria
TIAS
Jan. 1, 1999
Bangladesh
TIAS
Jan. 1, 2007
Barbados
TIAS 11090
Jan. 1, 1984
1991-2 C.B. 436
1991-2 C.B. 466
Protocol
TIAS
Jan. 1, 2005
Belgium
TIAS
Jan. 1, 2008
Bulgaria
TIAS
Jan. 1, 2009
Canada
TIAS 11087
Jan. 1, 1985
1986-2 C.B. 258
1987-2 C.B. 298
2
Protocol
TIAS
Jan. 1, 2009
China, People’s Republic of
TIAS 12065
Jan. 1, 1987
1988-1 C.B. 414
1988-1 C.B. 447
Commonwealth of Independent
States
3
TIAS 8225
Jan. 1, 1976
1976-2 C.B. 463
1976-2 C.B. 475
Cyprus
TIAS 10965
Jan. 1, 1986
1989-2 C.B. 280
1989-2 C.B. 314
Czech Republic
TIAS
Jan. 1, 1993
Denmark
TIAS
Jan. 1, 2001
Protocol
TIAS
Jan. 1, 2008
Egypt
TIAS 10149
Jan. 1, 1982
1982-1 C.B. 219
1982-1 C.B. 243
Estonia
TIAS
Jan. 1, 2000
Finland
TIAS 12101
Jan. 1, 1991
Protocol
TIAS
Jan. 1, 2008
France
TIAS
Jan. 1, 1996
Protocol
TIAS
Jan. 1, 2009
Germany
TIAS
Jan. 1, 1990
Protocol
TIAS
Jan. 1, 2008
Greece
TIAS 2902
Jan. 1, 1953
1958-2 C.B. 1054
T.D. 6109, 1954-2 C.B. 638
Hungary
TIAS 9560
Jan. 1, 1980
1980-1 C.B. 333
1980-1 C.B. 354
Iceland
TIAS 8151
Jan. 1, 2009
India
TIAS
Jan. 1, 1991
Chapter 6 Tax Treaty Benefits
Page 35

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