Rev. Proc. 80-18

Section 1. Purpose

The purpose of this revenue procedure is to set forth procedures for taxpayers to follow in applying certain provisions of the United States-United Kingdom Income Tax Convention, signed on December 31, 1975, as amended by an Exchange of Notes, signed on April 13, 1976, and Protocols, signed on August 26, 1976, March 31, 1977, and March 15, 1979 (the "Convention"), page 394, this Bulletin. The provisions of the Convention that are the subject of this revenue procedure concern: (1) payments from the United Kingdom of a tax credit representing United Kingdom Advance Corporation Tax to qualifying U.S. shareholders of United Kingdom corporations; and (2) U.S. tax consequences of the Convention for United Kingdom residents in regard to amounts with respect to which U.S. tax has been paid prior to April 25, 1980, or is due for periods prior to April 25, 1980 (the date the Convention enters into force). The provisions of the Convention and the rules for its application are described and explained in the Technical Explanation of the Convention prepared by the Department of the Treasury (the "Treasury Explanation"), page 455, this Bulletin.

Sec. 2. Background

In 1973, the United Kingdom adopted a new system of corporate taxation that partially integrates its corporate and individual income taxes. Under this system, Advance Corporation Tax ("ACT") is levied on a United Kingdom corporation upon the payment of a dividend by that corporation to its individual shareholders. ACT is an advance payment in partial satisfaction of the corporation's general corporate tax ("mainstream tax") liability.

The rate of ACT has varied since 1973 but is currently 3/7 (approximately 42.86 percent) of the dividend. At the corporate level, ACT is generally credited against the distributing corporation's mainstream tax for the year of the distribution and, if in excess of the part of that year's mainstream tax that may be offset, under United Kingdom law, by ACT (or if there is no mainstream tax), may be carried back two years and carried forward indefinitely. At the shareholder level, ACT paid by the distributing corporation is allowed as a credit against the shareholder's own income tax liability or paid in cash to the extent that the ACT credit exceeds the shareholder's own income tax liability. The shareholder must include in taxable income the sum of ACT and the dividend received; that is, the dividend is "grossed up" by the amount of ACT paid by the distributing corporation.

In the absence of a specific tax treaty provision, ACT is not credited or refunded to persons not resident in the United Kingdom. Article 10 (Dividends) of the Convention provides for a payment from the United Kingdom of a tax credit ("refund") of ACT to qualifying U.S. taxpayers and allows the United Kingdom to reduce the refund by an amount that serves the function of a withholding tax.

Other provisions of the Convention affect the computation of the U.S. foreign tax credit for United Kingdom taxes, including the portion of ACT that is not refunded to U.S. corporations owning, directly or indirectly, 10 percent or more of the voting stock of a distributing United Kingdom corporation ("direct investors"). Section 3 of the revenue procedure explains the procedures applicable to these ACT related matters.

The Convention also contains provisions regarding the U.S. tax applicable to income of residents of the United Kingdom. Certain of these provisions result in a different U.S. tax liability from that provided for in the Income Tax Convention between the United States and the United Kingdom of Great Britain and Northern Ireland effective for taxable years beginning on or after January 1, 1945, T.D. 5569, 1947-2 C.B. 100, as amended by Protocols signed on June 6, 1946, T.D. 5569, 1947-2 C.B. 100, May 25, 1954, 1957-1 C.B. 665, August 19, 1957, 1958-2 C.B. 1078 and March 17, 1966, 1966-2 C.B. 582 (the "1945 Convention"). Under Article 28 (Entry Into Force) of the Convention, the 1945 Convention ceases to have effect in the United States in respect of withholding taxes for amounts paid or credited on or after January 1, 1975 and, in respect of other taxes, for taxable years beginning on or after January 1, 1975. Under paragraph (4) of Article 28, however, if any provision of the 1945 Convention would have afforded greater relief than the Convention, the provision of the 1945 Convention has effect in the United States for any taxable year beginning prior to January 1, 1976.

Thus, the Convention applies for U.S. tax purposes to amounts with respect to which U.S. tax has been paid prior to April 25, 1980 or is due for periods prior to April 25, 1980. Section 4 of this revenue procedure explains the procedures applicable to the payment or refund of U.S. tax with respect to such amounts.

Sec. 3. Application of ACT Refunds to United States Shareholders

.01 Amount of ACT Refunds. Paragraph (2)(a) of Article 10 (Dividends) provides a mechanism whereby U.S. direct investors and others who are U.S. residents and hold stock in a corporation resident in the United Kingdom, within the meaning of paragraph (1)(a)(ii) of Article 4 (Fiscal Residence) (a "United Kingdom corporation"), may avail themselves of the benefits of the shareholder credit available, in the absence of the Convention, only to United Kingdom residents. Such benefits will be available to U.S. residents as long as ACT credit is allowed in the United Kingdom to individual United Kingdom residents. Paragraph (2) of Article 10. Otherwise, United Kingdom taxation of dividends derived by U.S. residents from a corporation resident in the United Kingdom will be limited to 15 percent of the gross amount of the dividends. Paragraph (1) of Article 10.

Under paragraph (2)(a) of Article 10, separate rules are provided for the taxation of dividends beneficially owned by U.S. direct investors and for the taxation of dividends beneficially owned by other U.S. residents ("portfolio investors"). For portfolio investors, paragraph (2)(a)(ii) of Article 10 provides for the refund by the United Kingdom of the full amount of ACT paid with respect to a dividend. This refund is reduced, however, by a 15-percent withholding on the sum of the dividend and the ACT refund. For direct investors, paragraph (2)(a)(i) of Article 10 provides for the refund by the United Kingdom of an amount equal to one-half of the ACT paid with respect to a dividend. This refund is reduced, however, by a 15-percent withholding on the sum of the dividend and the portion of ACT refunded (one-half).

.02 Shareholders Entitled to ACT Refunds. Shareholders entitled to ACT refunds include only residents of the United States, within the meaning of paragraph (1)(b)(i) and (ii) of Article 4 (Fiscal Residence), that derive and beneficially own dividends paid by a corporation resident in the United Kingdom.

Paragraph (4) of Article 10 (Dividends) provides that ACT refunds are not available to U.S. shareholders who have a permanent establishment in the United Kingdom or perform personal services from a fixed base therein if the holding with respect to which the dividends are paid is effectively connected with the permanent establishment or fixed base. Paragraph (7) of Article 10 provides that an ACT refund is not available in certain circumstances where tax avoidance may occur. Paragraph (7) is explained in the Treasury Explanation.

Pursuant to paragraph (2) of Article 1 (Personal Scope), an ACT refund is not available to a U.S. corporation that is also a resident of the United Kingdom within the meaning of paragraph (1)(a)(ii) of Article 4. However, an ACT refund is available to qualifying shareholders with respect to a dividend from a U.S. corporation that is also a resident of the United Kingdom.

U.S. shareholders are entitled to ACT refunds based on whether they meet the standards of the Convention as of the time the United Kingdom corporation paid the dividend subject to ACT that is refundable under the Convention.

.03 Effective Dates for ACT Refunds. The ACT refunds described in paragraph (2)(a)(i) of Article 10 (Dividends) are available to direct investors for dividends with respect to years of assessment beginning on or after April 6, 1975.

The ACT refunds described in paragraph (2)(a)(ii) of Article 10 are available to portfolio investors for dividends with respect to years of assessment beginning on or after April 6, 1973. A dividend paid on or after April 1, 1973, and before April 6, 1973, shall be treated for tax purposes as paid on April 6, 1973. The year of assessment referred to in the Convention (and in this paragraph .03) is the United Kingdom general income tax year, which begins on April 6 of each year.

.04 Year of Inclusion of ACT Refunds. Paragraph (2)(a)(iii) of Article 10 (Dividends) provides that for U.S. tax credit purposes the sum of a dividend and ACT refund paid by the United Kingdom to a U.S. corporation or other U.S. resident, without reduction for the amount withheld thereon, shall be treated as a dividend. For U.S. income tax purposes such amount must be included in the shareholder's gross income in the year the shareholder becomes entitled to such a refund. Thus, a calendar year U.S. taxpayer must include refunds of ACT paid prior to April 25, 1980 in his income for 1980 and a fiscal year U.S. taxpayer must do so for the first taxable year ending after April 24, 1980.

.05 Allowance of Foreign Tax Credits With Respect to ACT Refunds. Paragraph (1) of Article 23 (Elimination of Double Taxation) provides that the United States shall allow to its citizens and residents a foreign tax credit for the appropriate amount of tax paid to the United Kingdom, subject to the limitations of the laws of the United States for the taxable year. These limitations include the provisions of sections 904, 905, and 907 of the Internal Revenue Code. The Treasury Explanation, this paragraph .05, and paragraph .06 below provide rules to be used in determining the U.S. foreign tax credit pursuant to Article 23.

Paragraph (1)(a) of Article 23 provides that, for purposes of applying the U.S. credit, the United Kingdom income tax, capital gains tax, corporation tax and petroleum revenue tax are considered to be income taxes for persons entitled to the benefits of Article 23. Paragraph (1)(b) of Article 23 provides that the amount of 5-percent or 15-percent withholding, as the case may be, under paragraph (2)(a)(i) or (ii) of Article 10 (Dividends) from the grossed-up dividend (the sum of the dividend and the ACT refund) is to be treated as an income tax imposed on the recipient of the dividend (the U.S. shareholder).

Paragraph (1)(c) of Article 23 provides, in addition, that the one-half of the ACT paid by a United Kingdom corporation that is not refunded to a U.S. direct investor and that would be credited or refunded to a United Kingdom individual resident is treated as an income tax imposed on the distributing United Kingdom corporation (rather than the U.S. shareholder). Under United Kingdom law, a United Kingdom corporation that pays ACT may, however, transfer to a related United Kingdom corporation the right to apply ACT against mainstream tax liability. Thus, for example, a United Kingdom subsidiary of a United Kingdom corporation may benefit from the parent's ACT payment by offsetting part or all of the ACT against its own liability for United Kingdom mainstream tax. In such a case, for U.S. foreign tax credit purposes and pursuant to Article 23, the parent corporation has not paid or accrued the unrefunded ACT offset against the subsidiary's mainstream tax and has contributed to the capital of the subsidiary an amount equal to the unrefunded ACT offset. The subsidiary is considered to have paid or accrued only mainstream tax paid or accrued in excess of the ACT offset, plus the amount of unrefunded ACT so offset.

For purposes of Articles 10 and 23 of the Convention, refunded ACT offset against the United Kingdom subsidiary's mainstream tax is a deemed distribution from such subsidiary to the United Kingdom parent corporation (and from the parent to the U.S. shareholder) only if and to the extent that such refunded ACT was not useable by the parent (inasmuch as the parent owes no mainstream tax) and was imposed with respect to profits distributed by the subsidiary to the parent and which were then immediately redistributed to the U.S. shareholder. In all other cases, refunded ACT is a deemed dividend distribution only from the United Kingdom parent corporation to the U.S. shareholder.

A U.S. direct investor seeking to claim an indirect foreign tax credit as provided in paragraph (1)(c) of Article 23 (and pursuant to section 902 or section 960 of the Code) for the one-half of the ACT not refunded to such direct investor must compute the credit pursuant to this revenue procedure and the rules and examples set forth in the Treasury Explanation. Those rules and examples attribute ACT to accumulated profits, state which years' accumulated profits have been distributed as actual dividend distributions and ACT refund "dividends," and establish which accumulated profits are attributable to a U.S. shareholder that owns less than all of the stock of a distributing United Kingdom corporation. The rules in the Treasury Explanation for attributing ACT refunds to accumulated profits apply whether ACT is refunded at the time of the payment of the dividend that is subject to the ACT or at a later date (e.g., because the Convention enters into force in 1980 with retroactive effect). Thus, a refund in 1980 of ACT imposed with respect to a prior dividend distribution is a dividend distribution out of the years' accumulated profits to which, under this revenue procedure and the rules of the Treasury Explanation, the ACT is attributable. Accumulated profits and earnings and profits are determined under U.S. principles under sections 902 or 960, as the case may be, and the regulations thereunder.

As stated in section 2.05 of this revenue procedure, the right to receive ACT refunds gives rise to income for U.S. income tax purposes. For U.S. direct investors that prior to April 25, 1980 received actual distributions and claimed foreign tax credits for ACT for which a refund can be obtained under the Convention, an adjustment is required for U.S. income tax purposes; the amount of any foreign tax credits previously claimed by the direct investor pursuant to section 902 or 960 of the Code with respect to ACT that is refundable as of April 25, 1980 must be reduced by the direct investor to the extent of the refundable ACT (without reduction for the 5 percent withheld under the Convention by the United Kingdom). Section 905(c) and section 1.905-1(c) of the Income Tax Regulations provide that if any credited tax payment is refunded, in whole or in part, the taxpayer shall immediately notify the Commissioner of Internal Revenue. For purposes of the Convention and this revenue procedure, the reference to immediate notification of the Commissioner shall be construed to mean notification within 120 days of the receipt of an ACT refund from the United Kingdom pursuant to the Convention. Notification is to be accomplished by submitting, to the Internal Revenue Service Center where the taxpayer files its income tax return, an amended income tax return accompanied by a revised Form 1116 or 1118, as the case may be, for each taxable year involved.

The 5 percent withheld by the United Kingdom at the time of such a refund of ACT may, pursuant to the Convention and section 6511(d)(3)(A) of the Code, be claimed by a U.S. direct investor as a foreign income tax paid or accrued. Under paragraph (2)(a)(i) of Article 10 (Dividends), the 5-percent withholding is imposed by the United Kingdom on the aggregate of the dividend and the ACT refund paid to the U.S. direct investor. In the case of refunds of ACT with respect to a dividend distribution prior to April 25, 1980, the portion of the 5-percent withholding that is attributable to the prior dividend distribution (and not attributable to the ACT refund) is a foreign income tax paid or accrued for the U.S. taxable year in which such prior dividend was included in income by the U.S. direct investor. Similarly, the portion of the 15-percent withholding by the United Kingdom on ACT refunds to U.S. portfolio shareholders that is attributable to a prior dividend received by such a shareholder is a foreign income tax paid or accrued for the U.S. taxable year in which the dividend was included in income by the U.S. shareholder. (Since for U.S. income tax purposes ACT is imposed on the distributing corporation, not the shareholder, U.S. portfolio shareholders are not entitled to a foreign tax credit for ACT. The 15-percent United Kingdom withholding authorized by Article 10 is, however, treated under the Convention as an income tax imposed on the U.S. shareholder.) The portion of the 5- and 15-percent withholdings attributable to the ACT refund (and not to the prior dividend distribution) is for U.S. purposes a foreign income tax paid or accrued in the year in which refundable ACT is taken into income for U.S. purposes.

.06 Exchange Rates. The rate of exchange between the United Kingdom pound and the U.S. dollar on April 25, 1980 differs from the rate at the time when ACT with respect to prior distributions was paid to the United Kingdom. The refund of ACT to a U.S. shareholder must be included in the shareholder's gross income at the rate of exchange in effect on April 25, 1980 unless the rate of exchange on the date of receipt of the refund differs from the April 25, 1980 rate, in which case the rate on the date of receipt applies. The same rate of exchange also applies for claiming a foreign tax credit for the full amount of the 5- and 15-percent withholdings provided for by the Convention (regardless of the years to which such withholdings are attributable).

The change in the exchange rate also has implications for the section 905(c) adjustment described in section 2.06 of this revenue procedure, which requires a reduction for any refundable ACT previously claimed as a creditable foreign tax. In the case of a U.S. direct investor entitled to an ACT refund and which previously claimed a deemed paid foreign tax credit under section 902, the section 905(c) adjustment requires a reduction for any refundable ACT previously claimed as a deemed paid credit. The amount of ACT claimed as a foreign income tax paid or accrued by the United Kingdom corporation is reduced (and accumulated profits in excess of foreign income taxes are increased) in United Kingdom pounds by the amount of such ACT that is refundable. The U.S. direct investor must then recompute the amount of its income and the deemed paid foreign tax credit with respect to the prior dividend distribution or distributions, translating the three elements of the deemed paid tax credit formula into U.S. dollars at the rate of exchange in effect at the time of the prior distribution or distributions. See Bon Ami, 39 B.T.A. 825 (1939).

In the case of a U.S. direct investor entitled to an ACT refund and which previously claimed a deemed paid foreign tax credit for ACT under section 960 of the Code, the section 905(c) adjustment requires a reduction for any refunded ACT previously claimed as a deemed paid credit. The amount of ACT claimed as a foreign income tax paid or accrued by the United Kingdom corporation is reduced (and earnings and profits is increased) in United States dollars using the April 25, 1980 rate or, if it is different from the April 25, 1980 rate, the rate on the date of receipt of the ACT refund. The U.S. direct investor must then recompute its income and deemed paid foreign tax credit with respect to the prior inclusion.

In the case of a U.S. corporation managed and controlled in the United Kingdom which previously claimed a foreign tax credit for ACT under section 901(b) of the Code, and which has U.S. shareholders entitled to an ACT refund, section 905(c) requires a reduction, for any refundable ACT previously claimed as a credit, using the U.S. dollar amount of the refundable ACT at the rate of exchange on April 25, 1980 or, if it is different from the April 25, 1980 rate, the rate of exchange in effect on the date of receipt of the ACT refund.

.07 Manner of Claiming ACT Refunds from United Kingdom. A U.S. shareholder claiming ACT refunds as provided in paragraph (2)(a) of Article 10 must make such claim on the appropriate United Kingdom form. The appropriate United Kingdom forms are: 1) U.S. 7/Credit, for a U.S. direct investor to obtain authorization for a United Kingdom corporation to distribute future dividends with ACT refunds; 2) U.S./Corporation/Credit, for a U.S. corporation owning less than 10 percent of the voting stock of a distributing United Kingdom corporation, for a U.S. direct investor with respect to ACT which is not subject to a claim for relief pursuant to U.S. 7/Credit (including ACT paid with respect to dividends distributed prior to April 25, 1980), and for any other U.S. resident other than an individual (e.g., a partnership or a trust); 3) U.S./Individual/Credit, for U.S. individual residents. (U.S. persons must use other United Kingdom forms for relief under the Convention from United Kingdom tax on other items of income: 1) U.S./Individual (interest, royalties, pensions, annuities, alimony); 2) U.S./Corporation (interest, royalties).) In the United States the United Kingdom forms for ACT refunds may be obtained from the Office of International Operations, Internal Revenue Service, 1325 K Street, NW, ATTN: Taxpayer Service Division, Room 900, Washington, DC 20225. In the United Kingdom forms may be obtained from the Inspector of Foreign Dividends, Lynwood Road, Thames Ditton, Surrey, England, KT70DP.

The first claim under the Convention by a U.S. resident for an ACT refund should be initiated by filling out the appropriate United Kingdom form (in duplicate) and filing it with the Director of the Internal Revenue Service Center with which the shareholder's last U.S. income tax return was filed, so that it can be certified. The Service Center will transmit such United Kingdom forms that it certifies to the United Kingdom Inspector of Foreign Dividends. Because certification by the appropriate Service Center Director is necessary, the shareholder or the shareholder's representative should send the appropriate form to the appropriate Service Center for processing in sufficient time to make a timely claim for refund in the United Kingdom. Claims for ACT refunds must normally be made, under United Kingdom law, within 6 years of the end of the year of assessment in which a dividend distribution is made. Under the United Kingdom system the year of assessment ends on April 5. In addition, paragraph (7) of Article 28 (Entry Into Force) provides a three-year period after the end of the calendar year in which the Convention enters into force to obtain refunds of taxes pursuant to the Convention, notwithstanding the expiration of the period of limitations provided by United Kingdom internal law.

Any claim for ACT refunds by a U.S. resident after the first claim does not require prior certification by an Internal Revenue Service Center. The appropriate United Kingdom forms should be filed in such cases directly with the United Kingdom Inspector of Foreign Dividends.

Sec. 4. Application of United States Tax on United Kingdom Residents

.01 Refunds of U.S. Tax. Certain provisions of the Convention reduce U.S. tax of United Kingdom residents below the amount due under the provisions of the 1945 Convention. For example, dividends paid by a U.S. corporation to a corporation which is a resident of the United Kingdom which owns 10 percent or more of the voting stock of the U.S. corporation paying the dividend is subject to a U.S. tax of 5 percent of the dividend pursuant to paragraph (2)(b)(i) of Article 10 (Dividends). Under paragraph (1) of Article VI of the 1945 Convention, dividends beneficially owned by a resident of the United Kingdom were subject to U.S. tax at a rate of 15 percent. Article 28 (Entry Into Force) provides that the Convention applies in the United States to taxes withheld at source after January 1, 1975. Consequently, a resident of the United Kingdom which previously qualified for the 15-percent rate under paragraph (1) of Article VI of the 1945 Convention and which qualifies for the 5-percent rate under paragraph (2)(b)(i) of Article 10 is entitled to a refund of U.S. tax. The reduction to 5 percent applies to dividends paid on or after January 1, 1975.

The benefits of Article 10 are not available to a United Kingdom resident which is a U.S. corporation.

Another reduction in U.S. tax is provided by virtue of paragraph (2)(a) of Article 2 (Taxes Covered) and paragraphs (1) and (6A) of Article 7 (Business Profits). These provisions of the Convention state that insurance or reinsurance premiums received by certain United Kingdom enterprises are entitled to exemption from U.S. taxes otherwise imposed on insurance premiums paid to foreign insurers or reinsurers. The term "United Kingdom enterprise" includes a corporation, but only if the corporation is organized outside of the United States and is managed and controlled in the United Kingdom.

Other provisions of the Convention, such as paragraph (1) of Article 17 (Artistes and Athletes), paragraph (1) of Article 20 (Teachers) (with respect to researchers), and paragraph (2) of Article 18 (Pensions) (with respect to alimony), may also give rise to refunds of U.S. tax to certain United Kingdom residents.

A United Kingdom resident seeking a refund of U.S. income taxes pursuant to the Convention may obtain such refund by filing Forms 1040NR, 1040X, 1120F or 1120X, as the case may be, with the Philadelphia Service Center. Pursuant to paragraph (7) of Article 28, refunds may be obtained by filing the appropriate income tax form with the Philadelphia Service Center for certain U.S. taxable years with respect to which the U.S. statute of limitations has expired. A separate income tax form must be filed for each taxable year.

.02 Additional U.S. Tax Due. Certain provisions of the Convention eliminate U.S. tax benefits previously available to United Kingdom residents under the provisions of the 1945 Convention; thus, certain United Kingdom residents are subject to additional U.S. tax liability. (No provision of the Convention increases the U.S. tax of a United Kingdom resident above the amount due under the Code in the absence of the Convention.) For example, Article 6 (Income from Immovable Property (Real Property)) allows the United States to impose the 30-percent tax of Code sections 871(a) and 881 on fixed or determinable income from real property that is not effectively connected with the conduct of a trade or business in the United States. In contrast, Article IX of the 1945 Convention limited the U.S. tax on certain mineral royalties and real property rents to 15 percent if derived by a United Kingdom resident not engaged in trade or business in the United States. The 30-percent U.S. tax is due pursuant to the Convention with respect to any taxable year beginning on or after January 1, 1976. Thus, certain mineral royalties and real property rents paid for a U.S. taxable year beginning on or after January 1, 1976 are subject to an increase in U.S. tax (15 percent of the remittance) under the Convention. Other provisions of the Convention which may result in an increase in U.S. tax due include the provisions of Articles 13 (Capital Gains) and 17 (Artistes and Athletes).

The additional U.S. tax due for all open U.S. taxable years must be remitted to the Philadelphia Service Center along with Form 1040NR, 1040X, 1120F or 1120X, as the case may be, for each such taxable year.

.03 Withholding. Every person required to withhold any U.S. tax pursuant to the Code must, with respect to payments entitled to the benefits of the Convention, withhold U.S. tax pursuant to the provisions of the Convention only with respect to amounts paid on or after April 25, 1980. A non-resident alien or foreign corporation claiming the benefits of the Convention and seeking a reduction in or exemption from withholding of U.S. tax must satisfy any applicable requirements of the Code such as sections 1441, 1442, and 1461, and the regulations thereunder.

.04 Interest. Pursuant to Article 28 (Entry Into Force) and for purposes of section 6601 of the Code, the last date prescribed for payment of U.S. tax due for U.S. taxable years ending on or before April 24, 1980 shall be April 26, 1980, but only with respect to any additional U.S. tax due solely because the provisions of the Convention provide less relief from U.S. taxes than do the provisions of the 1945 Convention. Pursuant to Article 28 and for purposes of section 6611, the date of overpayment shall be considered to be April 25, 1980, but only with respect to refunds of U.S. tax due solely because the provisions of the Convention are more favorable than the provisions of the 1945 Convention.

Section 5. Inquiries

Inquiries regarding this revenue procedure may generally be addressed to the Commissioner of Internal Revenue, Attention: T:C:C:3, 1111 Constitution Avenue, NW, Washington, DC 20224. Inquiries concerning the filing of forms may be addressed to the Taxpayer Service Division of the I.R.S. Office of International Operations (address stated in section 3.07 of this revenue procedure), 202-566-5941 (not a toll-free number).

Section 6. Effective Date of This Revenue Procedure

This revenue procedure is effective on the date of its publication and applies to the taxable years affected by the Convention.

¹ Also released as News Release IR-80-57, dated April 25, 1980.