7 August 2001

See contents of full IRS Handbook of Criminal Investigation: http://cryptome.org/irs-ci/irs-ci.htm

## Handbook 9.13 INTERNATIONAL INVESTIGATIONS Chapter 2 TREATIES, MUTUAL ASSISTANCE LAWS, SIMULTAINEOUS INVESTIGATION PROGRAMS, AND AGREEMENTS
### Contents [9.13] 2.1 OVERVIEW [9.13] 2.2 TREATIES ON MUTUAL ASSISTANCE IN CRIMINAL MATTERS [9.13] 2.2.1 U.S.--Italy Treaty On Mutual Assistance In Criminal Matters [9.13] 2.2.2 U.S.--Netherlands Treaty On Mutual Assistance In Criminal Matters [9.13] 2.2.3 U.S.--Swiss Treaty On Mutual Assistance In Criminal Matters [9.13] 2.3 SWISS MUTUAL ASSISTANCE LAW (IMAC) [9.13] 2.4 SIMULTANEOUS CRIMINAL INVESTIGATION PROGRAM (SCIP) [9.13] 2.4.1 SCIP--Case Selection [9.13] 2.4.2 SCIP--Exchanging Information [9.13] 2.4.3 SCIP--Grand Juries [9.13] 2.4.4 SCIP--Witnesses [9.13] 2.4.5 SCIP--Disposition of Investigations [9.13] 2.4.6 SCIP--Travel [9.13] 2.4.7 SCIP--Disclosure and Publicity [9.13] 2.5 UNITED STATES--UNITED KINGDOM AGREEMENT FOR CAYMAN ISLAND NARCOTICS ASSISTANCE Exhibit [9.13] 2-1 United States-Canada Simultaneous Criminal Investigation Program Exhibit [9.13] 2-2 Certificate
### [9.13] 2.1 (10-19-1998) OVERVIEW
Information from foreign countries can be obtained through the following legal mechanisms: Treaties on mutual Assistance in Criminal Matters. Mututal Assistance Laws. Simultaneous Criminal Investigation Programs (SCIP). Agreements. Procedures for foreign travel and obtaining official passports are found in Handbook 9.11 Chapter 2 entitled Travel.
### [9.13] 2.2 (10-19-1998) TREATIES ON MUTUAL ASSISTANCE IN CRIMINAL MATTERS
The United States currently has Mutual Legal Assistance Treaties (MLAT) with a number of countries. These treaties provide a vehicle to obtain testimony and tangible evidence from each country. The treaties offer a wide range of assistance from the judicial and executive authorities of the counties involved. Each treaty designates the Attorney General as the Competent Authority for the United States who must handle requests under the treaty and whose approval is necessary for all requests. The Attorney General has delegated these powers and duties to the Assistant Attorney General of the Criminal Division. Pursuant to a request under the treaty, the requested authorities may: Supply official records. Locate persons. Provide service of process. Execute search and seizures of property. Arrange for the appearance of witnesses or experts before the relevant judicial authority. Secure extraditions. Transfer accused persons needed in the United States. Exchange relevant information relating to the laws, regulations, and international practices in criminal matters of the Contracting State. Requests for assistance pursuant to an administrative case must be made via memorandum by the Chief, Criminal Investigation (CI), with concurrence of the Director of Investigations (DI), to the Assistant Commissioner, CI Attn: Chief, Money Laundering and International, OP:CI:O:N:M. The Assistant Commissioner, CI will coordinate requests with the Office of International Affairs, Criminal Division of the Department of Justice. Requests should contain the following items: The subject matter and the nature of the investigation or proceeding; The principal need for the evidence or information sought; The full name, place and date of birth, address and any other available information, such as nationality, which may aid in the identification of person or persons who are the subjects of the investigation or proceeding; The name, address and nationality of the person whose testimony or statements are sought, or from whom documents, records, or articles of evidence are requested; and A description of the documents, records or articles of evidence to be produced or preserved, and of the manner in which they should be reproduced or authenticated. The request, insofar as possible and to the extent necessary, shall also include: A description of the particular procedure to be followed, if any; A statement as to whether sworn testimony or statements are required; and A description of the information, statement or testimony sought.
### [9.13] 2.2.1 (10-19-1998) U.S.--Italy Treaty On Mutual Assistance In Criminal Matters
The MLAT with Italy allows for compulsatory testimony in the United States of a witness in Italy if such witness could be compelled to appear and testify in similar circumstances in Italy, and if the Central Authority of the United States certifies that the witness' testimony is relevant and material. It also allows for the immobilization and forfeiture of assets in Italy to the United States in emergency situations.
### [9.13] 2.2.2 (10-19-1998) U.S.--Netherlands Treaty On Mutual Assistance In Criminal Matters
The U.S.-Netherlands MLAT also applies to the Netherlands Antilles. However, Netherlands Antilles reserves the right to refuse assistance in cases involving fiscal (tax) offenses.
### [9.13] 2.2.3 (10-19-1998) U.S.--Swiss Treaty On Mutual Assistance In Criminal Matters
This Treaty provides a vehicle to obtain testimony and tangible evidence from Switzerland. It was designed to deal primarily with the problem of Swiss Bank Secrecy Laws but it offers a wide range of assistance from the judicial and executive authorities of Switzerland. The Treaty applies to specified offenses which are mutually criminal, i.e., punishable under the laws of both the United States and Switzerland. It generally does not apply to violations with respect to taxes. However, it does apply to offenses relating to tax laws if: The offense is committed by a person reasonably suspected of being in the upper echelon of an organized crime group or of participating significantly in any important activity of such a group; Available evidence is insufficient to provide a reasonable prospect of successful prosecution of this person for the illegal activities of such group; It is reasonably concluded that requested assistance will substantially facilitate the successful prosecution of such person, and should result in his/her imprisonment for a sufficient period of time so as to have a significant adverse effect on the organized criminal group; and The securing of the information or evidence without the requested assistance is impossible or unreasonably burdensome. Another limitation especially applicable to tax cases relates to requested assistance with respect to two crimes; one to which the Treaty applies and one to which it does not. If, under Swiss Law, the first crime merges into the second, no assistance will be provided. An organized criminal group is defined by the Treaty. The elements of such a group, without any one of which the special organized crime provisions will not apply, are: An association or group of persons combined together; Association for a substantial or indefinite period; Purpose of association; monetary or commercial gains for itself or others, and illegal means of obtaining these gains; Carrying out purpose in a methodical and systematic manner. This is under acts or threats of violence or other acts which are likely to intimidate and are mutually criminal, and either, striving to obtain influence in politics or commerce, especially unpolitical organizations, public administrations, the judiciary, commercial enterprises, employers' associations, labor unions or other employees' associations, or association with a similar (organized crime) group which strives to obtain such influence. Requests for assistance must be made according to Procedures detailed in IRM 9.13.2.2, Treaties on Mutual Assistance in Criminal Matters, and must include the following elements: An introductory paragraph naming the authority on whose behalf the request is being made, the offense being investigated, a brief statement of the need for the evidence, identification of the subject of the investigation, and a concise statement of what assistance is requested. A description of the offense in concise terms. State the code section violated. Include facts of the case, showing that the offense has taken place or your reasons for believing the offense has taken place. A statement of the need for assistance and how the evidence sought fits into the proof of the case, e.g., to prove one or more of the elements of the crime or to show a motive. A statement of the full name, place and date of birth, address, and any other information which may aid in the identification of the persons who are at the time of the request the subject of the investigation. Also include the person's citizenship. A statement naming witnesses or other persons who may be affected by the request, et, joint bank account holders. The statement as to any particular procedure that is requested. e.g., the use of compulsory process for documents before notice to a witness. A statement as to whether the testimony to be taken (if any) should be done under oath or not. A description of the information, statement or testimony sought. A description of documents, records or articles of evidence to be produced or preserved, the persons on whom they are to be obtained, and the desired method of reproducing or authenticating them. This description must be as specific as possible. Information as to the allowance and expenses to which a person appearing in the United States will be entitled. The dollar amount for attendance fees and per diem can be ascertained from 28 U.S.C. 1871. Information which provides reasonable suspicion under the organized crime provisions. Reasonable suspicion is less than reasonable cause.
### [9.13] 2.3 (10-19-1998) SWISS MUTUAL ASSISTANCE LAW (IMAC)
The International Mutual Assistance in Criminal Matters (IMAC) law presents an opportunity to obtain additional information, evidence and testimony previously not available under the Tax Treaty or Mutual Assistance Treaty. Swiss bank information, previously protected by Swiss Secrecy Laws, may be available for use in criminal tax fraud investigations providing the investigations disclose elements, other than intent or negligence, of criminal tax punishable according to Swiss law. Foreign prosecutors and criminal investigators have the same means of access to Swiss banking information as their Swiss colleagues. The evidence obtained under IMAC for a criminal tax fraud case may be used for civil tax fraud purpose, if the civil tax fraud involves the same set of facts, the same tax, and the same subjects as the criminal tax fraud case, and the subjects were found or pleaded guilty. However, specific permission must be obtained from the Swiss Competent Authority. The Swiss will provide assistance only if information, evidence or testimony requested is: related to an offense punishable according to Swiss law; used exclusively for a criminal investigation or criminal prosecution; will not be used for assessment or collection of taxes and, prepared in a similar format used for requests under the U.S.--Swiss Treaty on Mutual Assistance in Criminal Matters. Swiss law requires evidence of fraudulent conduct in fiscal fraud (tax fraud) cases. Fiscal fraud takes place, under Swiss law, when a person deprives the Government of substantial tax or customs revenue by a scheme in which the Government is misled in its efforts to determine the truth relative to the amount of tax liability. Incorrect information entered on income tax returns is not considered fraudulent conduct and income tax evasion is not considered fiscal fraud punishable by Swiss law. Examples of fraudulent conduct considered to be fiscal fraud are: submitting false or forged documents to support a tax claim; submitting false receipts to support business expenditures; submitting false or forged documents to conceal unreported income; failure to maintain required records supporting income and expenses; setting up a fraudulent apparatus, such as an offshore corporation, to skim unreported income, etc. All requests must show fraudulent conduct in the criminal tax fraud aspects of the investigation. Administrative investigation requests will be processed pursuant to IRM 9.13.2.2. Requests will be forwarded by the Chief, Money Laundering and International to the International function and a copy of the transmittal will be sent to Department of Justice. Grand Jury investigation requests will be routed directly through the U.S. Attorney's office to the Department of Justice. Requests should contain the following seven essential elements to ensure the Swiss authorities will act favorably: the facts of the investigation and what the facts are based on; violations of U.S. law and how these violations deprive the United States Government of revenue; how these acts would violate Swiss law if committed for the purpose of Swiss Fiscal Fraud; exactly what information we want and why we want them to furnish it; the reasons we believe evidence is in Switzerland and what we believe the information will prove; the persons involved, their roles in the tax fraud scheme, our intentions towards prosecuting them; and procedures we want the Swiss to use in order to ensure admissible evidence in a possible criminal prosecution. Requests should be submitted in a consistent format. The introductory paragraph; The statement of facts; The explanation of the violations; The description of the assistance requested; The need for the assistance requested; The list of persons involved; and, The description of procedures to be followed. Requests should be limited to only information, evidence and testimony absolutely essential in proving the violations. Requests should not include information or documents which theoretically may be available and interesting but are not absolutely necessary to prove the case. Sample copies of fraudulent documents, if available, should be sent with the request. Swiss authorities are likely to advise the taxpayer/client, etc., of the request and its content. It is also possible the written request itself may be furnished to the taxpayer/client. In addition, a taxpayer has the right to appeal the proposed release of any Swiss information.
### [9.13] 2.4 (10-19-1998) SIMULTANEOUS CRIMINAL INVESTIGATION PROGRAM (SCIP)
This section contains procedures concerning the Simultaneous Criminal Investigation Program. Currently this program is in effect with the countries of Canada, Italy, France and Mexico. The following procedures which explain the Canadian SCIP also apply to all countries with SCIP agreements. The objectives of the SCIP program are to: conduct investigations of individuals and/or companies involved in substantial tax violations in both countries and eliminate the problems caused by taxpayers using the border to avoid production of records and reporting of income. The Assistant Commissioner (International) is designated by Delegation Order No. 114, as revised, to administer the program in the United States.
### [9.13] 2.4.1 (10-19-1998) SCIP--Case Selection
The Chief, CI should only recommend cases for the program which have the potential for substantial liability and where there is a sound basis for believing the subject is committing violations in both countries. The Chief, CI, will forward any cases recommended for the program through the appropriate DI to the A/C, CI, Attn: Chief, Money Laundering and International. See Exhibit 9.13.2-1. The A/C, CI will inform the recommending district by memorandum of the action taken and send an information copy to the DI. If a case is not accepted for the program, it will be worked as a routine investigation. If additional facts are developed, the case may be submitted for reconsideration. If a case is approved for the program, the A/C, International will transmit a letter to the Competent Authority requesting the foreign country's participation. See Exhibit 9.13.2.-1 Conti. (1). When the Competent Authority of the foreign country recommends a case for the program, the Criminal Investigation Office of Money Laundering and International (OP:CI:O:N:M) will transmit a copy of the request to the appropriate IRS district through the DI. The District will evaluate the request within 60 calendar days and advise the A/C, CI of its decision by memorandum routed through the DI. If the District decides to participate, the A/C (International) will send a Competent Authority acceptance letter. See Exhibit 9.13.2-1 Conti. (2). If not, the A/C (International) will notify the foreign country's Competent Authority. Copies of all letters exchanged by the Competent Authorities will be provided to the Office of International Programs, Attn: International Exchanges and Activities Division (IN:I:A).
### [9.13] 2.4.2 (10-19-1998) SCIP--Exchanging Information
Once Competent Authority letters have been exchanged and accepted, the Chief, CI will designate a case manager. The participating foreign country will also designate a case manager. National Office CI, Office of Money Laundering and International (OP:CI:O:N:M) will coordinate an initial meeting to plan the investigative activity. The meeting will be held in the country which originated the request unless a mutually agreeable alternative location is determined. The A/C, CI will provide a list to the A/C (International) of individuals designated to participate in the initial and subsequent meetings. The list will identify the individuals by name, position, office, and security clearance. Names may be added or deleted as necessary. Subsequent meetings will be arranged by the case managers. The District will notify the Office of Money Laundering and International (CP:CI:O:N:M) so National Office may, at their option, participate. Informal exchanges of information may be made, but formal exchanges of information or documents must be made by the respective Competent Authorities. Only formally exchanged documents can be used for evidentiary purposes. Information and documents to be formally exchanged will be transmitted by a brief letter describing the documents and prepared for A/C (International) signature. See Exhibit 9.13.2-1 Conti. (3). The Office of Money Laundering and International (OP:CI:O:N:M) will note each document exchanged This information was secured under the provision of an income tax treaty and its use and disclosure must be governed by the provisions of the treaty. Exchange of information is permissible in pre-indictment as well as post-indictment investigations. Information which may be exchanged includes: information related to the taxpayer, his/her companies, or named associates; information relating to specific transactions believed to involve the taxpayer, his/her companies, or named associates; Title 31 information which is needed for tax administration, although requests for Forms 4789, Currency Transaction Reports, must be made on a specific name basis since they do not fall within the routine information category of the present treaty.
### [9.13] 2.4.3 (10-19-1998) SCIP--Grand Juries
Grand juries can be used in simultaneous investigations either at the request of the IRS or the U.S. Attorney, subject to Department of Justice approval. Information from a U.S. grand jury may be furnished to the respective Competent Authority for tax administration purposes under a Rule 6(e) order. The treaty partner will be required to meet the requirements of showing a particularized need for the information and that the information is sought preliminarily to or in connection with a judicial proceeding. If a U.S. multi-agency grand jury uses information received under the auspices of the tax treaty in an indictment and/or at trial, the indictment must include tax charges and must show a nexus between the tax charges and any other violations. Using the information in an indictment and/or at a trial that does not contain tax charges requires specific approval by the treaty partner.
### [9.13] 2.4.4 (10-19-1998) SCIP--Witnesses
The tax conventions with the respective SCIP countries contains no provisions requiring foreign witnesses to appear at trial. The resulting potential for trial problems should be evaluated both in making a request for a simultaneous investigation and during the investigation itself. If arrangements cannot be made for a witness to appear at trial, Rule 15 depositions or letters rogatory may be used.
### [9.13] 2.4.5 (10-19-1998) SCIP--Disposition of Investigations
Jeopardy or termination assessments which include information furnished through the program can be handled in the normal fashion, but the Canadian Competent Authority must be notified before such action is taken. Either country may withdraw from a simultaneous investigation at any time by advising the other country. If a district decides to withdraw: The Chief, CI, will submit a memorandum through the DI to the A/C, CI, Attn: Chief, Money Laundering and International (OP:CI:O:N:M), indicating the district is withdrawing from the investigation and why. The district will also discuss the withdrawal with the treaty counterpart designed case manager and document this in the memorandum. The A/C, CI will inform the A/C (International) of the action. The A/C, (International) will advise the Canadian Competent Authority by letter. The district will proceed with the investigation under normal guidelines, making any subsequent requests for information by collateral assistance requests. Prosecution reports are processed in the normal fashion with these added requirements: The Competent Authority or designated investigation manager should be informed of the submission. The transmittal memorandum to District Counsel/Department of Justice must identify the investigation as having been worked under the SCIP and include the anticipated date for filing of charges by the foreign country. Simultaneous indictments and/or filing of charges is preferred if circumstances permit, making close coordination by the designated investigation manages imperative.
### [9.13] 2.4.6 (10-19-1998) SCIP--Travel
All travelers on SCIP cases must initially complete a continuous travel Form 1321, Authorization for Official Travel. Thereafter, the Chief, Money Laundering and International will coordinate the processing with the Office of International Programs for authority to travel on a trip-by-trip basis. Requests for travel to Canada must be made ten calendar days before traveling and must include the investigation name; names, titles, and offices of those traveling; destination; and dates of travel. Requests submitted for travel to Canada less than ten calendar days before traveling must include a justification for emergency processing. The same travel authorization number will be used for each traveler throughout the fiscal year. Requests for travel to countries other than Canada need to adhere to the established time-frames prescribed in Handbook 9.11 Chapter 2, entitled Domestic and Foreign Travel.
### [9.13] 2.4.7 (10-19-1998) SCIP--Disclosure and Publicity
The tax treaty contains a secrecy clause restricting disclosure of information exchanged pursuant to the treaty. Access to such information is governed by IRC Section 6103 and may be exempt from disclosure under 5 USC 552(b) (3) or (j) (2). The Competent Authority should be alerted if any disclosure is contemplated. CI may disclose information obtained during a simultaneous investigation to other IRS personnel for tax administration purposes, but they must inform the Competent Authority or the designated investigation manager of the intended use of the information. Publicity in simultaneous or unilateral indictments should be handled in accordance with the procedures detailed in Handbook 9.3.2.
### [9.13] 2.5 (10-19-1998) UNITED STATES--UNITED KINGDOM AGREEMENT FOR CAYMAN ISLAND NARCOTICS ASSISTANCE
The United States-United Kingdom Agreement for Cayman Islands Narcotics Assistance became effective on August 29, 1984, and established guidelines and procedures for securing documentary information located in the Cayman Islands including, but not limited to, bank and business records as well as official government records for use in United States investigations and proceedings involving illegal narcotics trafficking. This agreement applies to all offences or ancillary civil or administrative proceedings taken by the United States Government or its agencies connected with, arising from, related, or resulting from any narcotics activity referred to in Article 36 of the Single Convention on Narcotics Drugs, 1961, as amended by the 1961 Protocol and falling within the jurisdiction of the United States. The matter need not specifically involve narcotics charges so long as the investigation or case is simply connected with, arising from, related to, or resulting from any narcotics activity. For example, a criminal tax investigation involving the net worth theory of proof could very well qualify for assistance under the agreement if the likely source of income of the target (or defendant) is narcotics trafficking. This agreement is not restricted to matters that result in a criminal recommendation. Information could be requested under the agreement for records necessary to make jeopardy assessments. Any information obtained under the agreement in a grand jury investigation should be treated in accordance with IRM 9.13.2.2 et seq. In an administrative investigation, the information obtained would be available for civil purposes. Under this agreement records will be obtained from the Cayman Islands via a Certificate as follows: The United States Attorney General will issue to the Attorney General of the Cayman Islands a certificate stating that specified records located in the Cayman Islands are relevant to a narcotics related case or investigation in the United States (Exhibit 9.13.2-2). The certificate will not contain any information about the case other than the docket, grand jury or investigation number. If the investigation is administrative, the Attorney General's Certificate procedure is prereferral assistance and does not constitute a prosecution referral as described in IRC 7602(c). The certificate must contain a description of the documentary information sought. The certificate should contain the name of the specific Cayman Bank, business or other entity where the documents are located, and if known, the account number or other identifying information. For both grand jury and administrative investigations, and in any follow-up consultations with the Department of Justice (DOJ), the requesting agent must provide DOJ with sufficient information regarding the investigation to enable the Attorney General to determine whether a certificate under the agreement should be issued. Any such information which might be considered return information or taxpayer return information under IRC 6103 may be so disclosed under the exceptions provided in IRC 6103(k)(4) or IRC 6103(k)(6) or both. Upon receipt of a certificate the Cayman Attorney General will issue to the custodian of the documentary information a notice requiring the custodian to produce to the Cayman Attorney General the documentary information requested in the custodian's possession, custody or control within 14 days of the date of the said notice unless that period is extended for good cause with the concurrence of the US Attorney General or is shortened with the concurrence of the Cayman Attorney General. If the custodian of the documents refuses to produce the documentary information, he will be liable to a substantial fine and imprisonment, and the Cayman Government will seize the documentary information. The Cayman Government must see that authentication and foundation testimony, necessary for the admission of the documentary information, be provided by the custodian or other appropriate individual. This testimony can take the form of affidavit, deposition in the Cayman Islands, or voluntary appearance by the appropriate witness in the United States. The United States has agreed that these procedures will be the exclusive means (i.e., in lieu of compulsory process) used to obtain documentary information from the Cayman Islands in narcotics related investigations. Therefore, until further notice, no summonses for documents located in the Cayman Islands in narcotics related investigations should be issued to banks or businesses in the United States. Any summonses outstanding will not be enforced without the express prior approval of DOJ. This does not apply to summonses seeking substantive witness testimony from Cayman residents found in the United States or to those seeking Cayman records in cases or investigations which are unrelated to drug trafficking. Summonses may be issued to institutions in this country for records located in the Cayman Islands on nonnarcotic related investigations as well as for records not located in the Cayman Islands in narcotics related investigations. See Multifunctional Handbook, 109.1, Summons. DOJ will carefully follow the progress of all requests under the agreement and monitor the effectiveness of the agreement in meeting the United States' investigative needs. To this end, it is essential that each initiator who utilizes the agreement coordinate closely all requests with the Assistant Commissioner, CI, via, Attention: Chief, Money Laundering and International (OP:CI:O:N:M). During grand jury investigations, the following procedures will be used to request that a certificate be issued to obtain records under the terms of this agreement: The investigating special agent will prepare a request, in letter format addressed to the Office of International Affairs, Criminal Division, DOJ, signed by the appropriate US Attorney, Strike Force Chief, or head of a Presidential Drug Task Force. Copies of the letter will be sent to the Assistant Commissioner, CI, Attention: Chief, Money Laundering and International through the appropriate Director of Investigations. Upon compliance by the Cayman government, the records requested and Attestation of Authenticity of Official Records (Exhibit 9.13.2-2 Conti. (1)), and/or Affidavit with Respect to Documents of a Regularly Conducted Business Activity (Exhibit 9.13.2-2 Conti. (2)), will be forwarded to DOJ. These will subsequently be forwarded to the requesting field attorney. The Chief, CI should notify, by memorandum, the Assistant Commissioner, CI, via, Attention: Chief, Money Laundering and International when the records are obtained. The memorandum should also state whether or not the records are complete. During an administrative investigation, the following procedures will be used to request that a certificate be issued to obtain records under the terms of this agreement: The investigating special agent will prepare a request letter addressed to the Tax Division, Criminal Section, Department of Justice, and signed by the Chief, CI. Copies of the letter will be sent to the Assistant Commissioner, CI, Attention: Chief, Money Laundering and International, thru: the appropriate DI. The Tax Division, Criminal Section, DOJ, after approval, will forward the letter and certificate to the Director, Office of International Affairs, Criminal Division, DOJ. Upon receipt of the records, the Chief, CI will forward a memorandum to the Assistant Commissioner, CI, Attention: Chief, Money Laundering and International, thru: the appropriate DI, and stating whether or not the requested records are complete. Exhibit [9.13] 2-1 (10/19/98) United States-Canada Simultaneous Criminal Investigation Program Exhibit [9.13] 2-1 (Cont.) (10/19/98) United States-Canada Simultaneous Criminal Investigation Program Exhibit [9.13] 2-1 (Cont. 3) (10/19/98) United States-Canada Simultaneous Criminal Investigation Program Exhibit [9.13] 2-1 (Cont. 4) (10/19/98) United States-Canada Simultaneous Criminal Investigation Program Exhibit [9.13] 2-2 (10/19/98) Certificate Exhibit [9.13] 2-2 (Cont.) (10/19/98) Certificate Exhibit [9.13] 2-2 (Cont. 3) (10/19/98) Certificate
### Internal Revenue Manual | ### Hndbk. 9.13 Chap. 2 TREATIES, MUTUAL ASSISTANCE LAWS, SIMULTAINEOUS INVESTIGATION PROGRAMS, AND AGREEMENTS | ### (10-19-1998)

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