IRS proposes significant revisions to Competent Authority procedures

Tax Controversy & Dispute Resolution ()
The Internal Revenue Service (IRS) on November 22 issued a proposed update and revision of the revenue procedure governing requesting Competent Authority assistance under U.S. tax treaties, principally the Mutual Agreement Procedure (MAP) article.  The IRS has requested comments on the proposed revenue procedure by March 10, 2014, and the proposed revenue procedure will not be finalized or effective until the comments are considered.