The US Internal Revenue Service (IRS) has published guidance regarding the mandatory arbitration procedure contained in the 2006 protocol to the UnitedStates-Germany  tax treaty that entered into force on 28 December 2007. The guidance is contained in IRS Announcement 2008-39. The 2006 protocol modified certain provisions of the tax treaty. Among other modifications, the protocol revises the mutual agreement procedure (MAP) in Art. 25 of the treaty to provide for mandatory arbitration of certain cases. The Announcement states that the competent authorities of both countries are currently developing the procedures for the arbitration process and that interim guidance is being...