Professional Documents
Culture Documents
SECTION 1. PURPOSE
Protocols dated June 14, 1983, March 28, 1984, March 17, 1995,
and July 29, 1997 ("the Treaty"), 1986-2 C.B. 258. Article
See also Rev. Proc. 96-13, 1996-1 C.B. 616, for an updated
SEC. 2. SCOPE
participation.
Delegation Order No. 114 (Rev. 10), Effective date: June 2, 1994.
SEC. 3. BACKGROUND
agreement."
entirely discretionary.
U.S. taxation.
the U.S. competent authority may require that the taxpayer obtain
information:
matter;
effect;
under examination;
thereafter;
statement to the effect that the facts upon which the ruling was
(International); and
the person or persons making the request and not by such person’s
assistance.
to grant relief will be made based upon all of the facts and
circumstances.
SEC. 8. FEES
15 of Rev. Proc. 97-1, 1997-1 I.R.B. 11, at page 46, requires the
DRAFTING INFORMATION
toll-free call).