[Code of Federal Regulations]
[Title 26, Volume 18, Parts 500 to 599]
[Revised as of April 1, 2000]
From the U.S. Government Printing Office via GPO Access
[CITE: 26CFR521.117]

[Page 153]
 
                       TITLE 26--INTERNAL REVENUE
 
     CHAPTER 1--INTERNAL REVENUE SERVICE DEPARTMENT OF THE TREASURY 
                               (Continued)
 
PART 521--DENMARK--Table of Contents
 
                       Subpart--General Income Tax
 
Sec. 521.117  Claims in cases of double taxation.

    Under Article XX of the convention, where the action of the revenue 
authorities of the contracting States has resulted in double taxation in 
respect of any of the taxes to which the convention relates, the 
taxpayer is entitled to lodge a claim with the country of which he is a 
citizen or, if he is not a citizen of either country, with the country 
of which he is a resident, or if the taxpayer is a corporation or other 
entity, with the country in which it is created or organized. Article XX 
further provides that should the claim be upheld, the competent 
authority of the country with which the claim is lodged may come to an 
agreement with the competent authority of the other country with a view 
to equitable avoidance of the double taxation. Such a claim on behalf of 
a United States citizen or corporation or other entity, or on behalf of 
a resident of the United States who is not a Danish citizen, shall be 
filed with the Commissioner of Internal Revenue, Washington, D.C. The 
claim should be set up in the form of a letter and should show fully all 
facts on the basis of which the claimant alleges that such double 
taxation has resulted. If the Commissioner of Internal Revenue 
determines that there is an appropriate basis for the claim under the 
convention, he will take the matter up with the Chief of the Taxation 
Department of the Ministry of Finance of Denmark with a view to 
arranging an agreement of the character contemplated by Article XX.