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Publication 570

Double Taxation(p23)

Mutual agreement procedures exist to settle issues where there is inconsistent tax treatment between the IRS and the taxing authorities of the following possessions.
These issues usually involve allocations of income, deductions, credits, or allowances between related persons; determinations of residency; and determinations of the source of income and related expenses.

Competent Authority Assistance(p23)

The tax coordination agreements between the United States and the possession tax departments contain provisions allowing the competent authorities of the United States and the relevant possession to resolve, by mutual agreement, inconsistent tax treatment by the two jurisdictions.
Due date
Send your written request for U.S. assistance under this procedure to:

Deputy Commissioner (International)
Large Business and International Division
Office of Tax Treaty
Internal Revenue Service
1111 Constitution Avenue, N.W.
Routing: MA3-322A
Washington, DC 20224-0002



Nonresident aliens generally must present their initial request for assistance to the relevant possession tax agency.

How to make your request.(p23)

Your request for competent authority assistance must be in the form of a letter addressed to the Deputy Commissioner (International) LB&I. The request must contain a statement that competent authority assistance is requested under the mutual agreement procedure with the possession and must include all the facts and circumstances relating to your particular case. You (or a person having authority to sign your federal return) must sign and date the request.
To avoid unnecessary delays, make sure you include all of the following information.
Before you submit your request for competent authority assistance check that you have included all the information listed in Revenue Procedure 2006–23, 2006–20 I.R.B. 900 available at

Credit or Refund(p23)

In addition to the tax assistance request, if you seek a credit or refund of any overpayment of U.S. tax paid on the income in question, you should file a claim on Form 1040X, Amended U.S. Individual Income Tax Return. Indicate on the form that a request for assistance under the mutual agreement procedure with the possession has been filed. Attach a copy of the request to the form.
Also, you should take whatever steps must be taken under the possession tax code to prevent the expiration of the statutory period for filing a claim for credit or refund of a possession tax.
See Revenue Procedure 2006-54, section 9, for complete information.