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b$.$ Complete the letter below, formally responding to Sonja.

SWFT$,$ LLP

$5191$ Natorp Boulevard

Mason, $OH45040$

October $19,2023$

Ms$.$ Sonja Bishop

Tile, Inc.

$100$ International Drive

Tampa, FL $33620$

Dear Ms$.$ Bishop:

This letter is in response to your request about information concerning a conflict between a U$.$S$.$ treaty with Spain and a Section of the Internal Revenue Code $($IRC$).$ The major reasons for treaties between the United States and certain foreign countries is to eliminate $$ taxation and to render mutual assistance in tax enforcement.

IRC $7852($d$)$ provides that if a U$.$S$.$ treaty is in conflict with a provision in the IRC, $$ will take general precedence. Rather, the more recent of the two

$$ precedence. In your case, the treaty with Spain

$$ precedence over the IRC Section.

A taxpayer $$ disclose on the tax return any positions where a treaty overrides a tax law. There is a penalty $($per failure$)$ for individuals who fail to disclose and a $ penalty $($per failure$)$ for corporations that fail to disclose.

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