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When should a U.S. MNE apply for ICAP

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A U.S. MNE should apply for ICAP (International Compliance Assurance Program) by one of the periodic application deadline dates published on the OECD website. The first three deadlines for submission of an application to participate in ICAP were 30 September 2021, 31 March 2022, and 30 September 2022. Future deadlines will be released on the OECD website in due course.

The application process involves submitting a "selection documentation package" as described in the ICAP Handbook. It is recommended that U.S. MNEs contact the IRS at lbi.icap@irs.gov for an initial consultation before submitting their application materials. This consultation provides an opportunity to discuss the ICAP process with IRS personnel and address administrative items, including the specific manner in which the selection documentation package must be filed with the IRS.

Sources:
IRM Part 4. Examining Process. Chapter 60. International Procedures. Section 11. International Compliance Assurance Program

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