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No, U.S. MNEs are not guaranteed acceptance to ICAP if they apply. The IRS will consider whether it is willing to act as the lead tax administration for a U.S. MNE based on the MNE's suitability for ICAP and the anticipated availability of IRS personnel. The IRS will explain the basis for its decision if it determines it is unable to act as the lead tax administration for an MNE. The IRS may also suggest that the MNE group consider re-submitting its selection documentation package at a later date.
Sources:
IRM Part 4. Examining Process. Chapter 60. International Procedures. Section 11. International Compliance Assurance Program
