Rev. Proc. 69-13

The Internal Revenue Service, in situations involving domestic subsidiaries, will entertain requests of United States controlling taxpayers for relief from "economic double taxation" similar to that granted under section 3 of Revenue Procedure 64-54, C.B. 1964-2, 1008, as amplified by Revenue Procedure 65-31, C.B. 1965-2, 1024, and as amended by Revenue Procedure 66-33, C.B. 1966-2, 1231. This "economic double taxation" can arise from the application of section 482 of the Internal Revenue Code of 1954 to transactions between a United States controlling taxpayer and one or more of its controlled domestic entities whose income was subject to foreign taxes.

However, the Service will entertain requests only for taxable years beginning prior to January 1, 1965, and only when (1) the request is submitted within the statutory period for filing claims for refund, and (2) the taxpayer's liability for the year involved has not been finally determined by offer in compromise, closing agreement, or court action.

Taxpayers who believe they are entitled to such relief should file a request for relief, together with all relevant information, with the District Director for the district in which the income tax returns for the year, or years, affected were filed.

¹ Also released as Technical Information Release 997, dated October 25, 1968.