Regulation section 301.6114-1 sets
forth the reporting requirement under Sec. 6114. Persons or
entities subject to this reporting requirements must make the
required disclosure on a statement attached to their return, in the
manner set forth, or be subject to a penalty. Regulation section
301.7701(b)-7(a)(4) (iv)(C) sets forth the reporting requirement
for dual resident S corporation shareholders who claim treaty
benefits as nonresidents of the United States.
US Code:
26
USC 6114 Name of Law: Treaty-based return positions
On behalf of this Federal agency, I certify that
the collection of information encompassed by this request complies
with 5 CFR 1320.9 and the related provisions of 5 CFR
1320.8(b)(3).
The following is a summary of the topics, regarding
the proposed collection of information, that the certification
covers:
(i) Why the information is being collected;
(ii) Use of information;
(iii) Burden estimate;
(iv) Nature of response (voluntary, required for a
benefit, or mandatory);
(v) Nature and extent of confidentiality; and
(vi) Need to display currently valid OMB control
number;
If you are unable to certify compliance with any of
these provisions, identify the item by leaving the box unchecked
and explain the reason in the Supporting Statement.