Internal Revenue Bulletin:  2006-4 

January 23, 2006 

TAX CONVENTIONS


Announcement 2006-6 Announcement 2006-6

This document announces the memorandum of understanding (MOU) signed by the U.S. and Japanese Competent Authorities concerning the meaning of the term “investment bank” under Article 11(3)(c)(i) of the U.S.-Japan income tax treaty.

Announcement 2006-7 Announcement 2006-7

This document announces the memorandum of understanding (MOU) signed by the U.S. and Canadian Competent Authorities concerning the principles, guidelines, and procedures to resolve disagreements about underlying facts and circumstances in cases that are referred to them under the mutual agreement procedure (MAP) article of the U.S.-Canada income tax treaty.

Announcement 2006-8 Announcement 2006-8

This document announces the mutual agreement between the U.S. and Mexican Competent Authorities that specifies the case in which fiscally transparent entities are entitled to treaty benefits and clarifies the procedures for claiming those benefits under the U.S.-Mexico income tax treaty.


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