This revenue procedure 2015-40
provides guidance on the process of requesting and obtaining
assistance under U.S. tax treaties from the U.S. competent
authority, acting through the Advance Pricing and Mutual Agreement
Program and the Treaty Assistance and Interpretation Team of the
Deputy Commissioner (International), Large Business &
International Division of the Internal Revenue Service. This
revenue procedure updates and supersedes Rev. Proc. 2006-54, 2006-2
C.B. 1035, and is being issued concurrently with Rev. Proc.
2015-41, 2015-35 I.R.B., which provides guidance with respect to
advance pricing agreements. This revenue procedure also reflects
modifications based on continuing internal monitoring of the
administrative procedures of the U.S. competent authority to ensure
that the administration of U.S. tax treaties is consistently
principled, effective, and efficient.
US Code:
26
USC 482 Name of Law: Allocation of income and deductions among
taxpayers
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.