The IRS issued Rev. Proc. 2015-40 recently, and this EY summary provides details re: the Limitation on Benefits (LOB) provisions for granting competent authority assistance.
The new rules highlight rules focusing on recent proposals for the US Model Tax Convention as well as the intent of BEPS re: “special regimes.”
These changes are critical to resolving issues, and the impact of double taxation, accompanying an increasing trend in foreign tax adjustments. This new procedure will become more visible as more countries implement BEPS guidelines via unilateral legislation and adoption of the OECD multilateral instrument.