On March 10, 2014, TEI submitted comments to the IRS regarding Notice 2013-78, which proposes substantial revisions to Revenue Procedure 2006-54 for requesting assistance from the U.S. competent authority under U.S. tax treaties. TEI’s comments focused on, among other things, the ability of the U.S. competent authority to expand the scope of mutual agreement procedure requests, the interaction between the U.S. competent authority and IRS exam and appeals, and the impact of the proposed revenue procedure on the compulsory payment rule for claiming a foreign tax credit.
TEI’s comments were prepared under the aegis of TEI’s U.S. International Tax Committee, whose chair is Jim Silvestri of Capsugel. Benjamin R. Shreck, TEI Tax Counsel, coordinated the preparation of TEI’s comments.