In the recent Rev. Proc. 2015-40, the IRS describes updated competent authority procedures for taxpayers seeking certain U.S. treaty relief. The new procedures, effective for requests on or after October 30, 2015, supersede those in Rev. Proc. 2006-54, although there is substantial overlap in the basic procedures. Some updates were previewed as proposals in Notice 2013-78, but a number of the final procedures differ from the notice due in large part to IRS attempts to respond to comments. Rev. Proc. 2015-40 represents the Treasury and IRS’s balancing of the goals of principled and efficient administration of and taxpayer access to the competent authority.