Prescribing the Procedures on Request for Information of Treaty Countries

April 9, 1985 REVENUE MEMORANDUM ORDER NO. 11-85 Subject : Prescribing the Procedures on Request for Information of Treaty Countries. To : All Internal Revenue Officers and Others Concerned. It shall be the policy of this Office to act without delay on all requests for information from our treaty partners under the exchange of information provision of our tax treaties. To implement this policy, the following orders are hereby issued for compliance by all concerned. 1. The International Taxation Division is hereby directed to coordinate, monitor and evaluate all request for information by treaty countries endorsed to it by the Commissioner for action. It shall determine where the required information may be obtained and forwarded the same directly to the Service, Office, Region, Division, District or Unit concerned. acd 2. Upon receipt of the request, the Offices concerned are hereby directed to produce the data requested under their custody, or which they can pick-up from the tax returns pending audit or investigation. If the information desired cannot be obtained unless an audit or investigation of taxpayer's income tax return is conducted, said return may be requisitioned from the revenue official in custody thereof, without securing prior approval from, or permission of, the Commissioner, and shall proceed to conduct the necessary audit on investigation. 3. The International Taxation Division shall secure information which is not available in the normal course of the administration of revenue laws but can be obtained without difficulty from other government agencies. 4. All information to be furnished shall include a brief explanation, remarks and/or background information relevant thereto, and shall be forwarded to the Commissioner, Attn.: The Chief, International Taxation Division. 5. The International Taxation Division shall consolidate all the information it receives and submit them, together with the necessary action, to the Commissioner for his signature. This order shall take effect immediately. (SGD.) TOMAS C. TOLEDO Acting Commissioner