The IRS Office of Chief Counsel (OCC) recently released a letter dated 11 April 2024 that responds to an information request regarding the 1989 U.S.-Germany income tax treaty, including the requirements that must be satisfied to obtain relief under Article 25 (Mutual Agreement Procedure) from the U.S. and German competent authorities. The main text of the letter is as follows: --- This letter responds to your request for information, -------------------------------, that was recently received by the IRS Office of Associate Chief Counsel International ("ACCI"). The information request raises various issues related to the 1989 U.S.-Germany income tax treaty (the "Treaty"),...