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@BobKamman wrote:

The one thing I learned from my days issuing Alien Tax Clearances in Washington DC is that most of IRS is clueless about taxation of non-citizens.

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You can say that again.  There's been more than one time I had to be transferred to different specialist units because the agents didn't understand the technicalities.

When I first joined this business doing international tax, there was a tax director who used to work for the HMRC (UK equivalence of the IRS).  He told me that agents there relied heavily on manuals (much like the IRS) rather than actual tax code and regulations.  Our value to client is to understand the law better than the agents so that we are able to make a strong and convincing argument for their cases.