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Publication 597

Competent Authority Assistance(p4)

Under Article XXVI, a U.S. citizen or resident can request assistance from the U.S. competent authority when the actions of Canada, the United States, or both, potentially result in double taxation or taxation contrary to the treaty. The U.S. competent authority may then consult with the Canadian competent authority to determine if the double taxation or denial of treaty benefits in question can be avoided. If the competent authorities are not able to reach agreement in a case, binding arbitration proceedings may apply.
Generally, you should file a competent authority request promptly after a competent authority issue arises or is likely to arise. Under certain circumstances, a competent authority request or a treaty notification must be filed within a certain time limit.
For requirements to file, and information that should be included in, a competent authority request, see Revenue Procedure 2015-40, 2015-35 I.R.B. 236, available at Additional information is available at
Your competent authority request should be addressed to:

Deputy Commissioner (International)
Large Business and International Division
Internal Revenue Service
1111 Constitution Ave., NW
Washington, D.C. 20224
(Attention: TAIT)

All mail should be sent to this mailing address, including regular mail, express mail, overnight mail, and mail sent by USPS, FedEx, UPS, or any other carrier.
In addition to a timely request for assistance, you should take the following measures: