Ezel / IRS Rulings / 200933035

CCA 200933035: Foreign government treated as foreign corporation for attribution rules

Number
200933035
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Definitions
Topics
Entity classification
Code sections
§ 7701, § 6110
Ruling dated
July 15, 2009
Publicly released
August 14, 2009
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 2009, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2009
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel Advice addressed the definition of “person” for attribution rules at issue in a taxpayer's case. It stated that a foreign government would be treated as a foreign corporation and therefore would meet the definition of a person under section 7701(a)(1). The advice was limited to the described attribution issue.

Ruling snapshot

  • Question: Would a foreign government be treated as a person under the attribution rules in section 7701(a)(1)?
  • Outcome: Advice given
  • Key authorities: IRC § 7701(a)(1)

Full text (IRS public release)

ID: CCA_2009071510334238 Number: 200933035
Release Date: 8/14/2009
Office:
UILC: 7701.00-00

From: ----------------
Sent: Wednesday, July 15, 2009 10:33:50 AM
To: -----------------------
Cc: -------------------------------------------
Subject: Requested Confirmation

-------

For purposes of the attribution rules at issue in your case, a foreign
government would be treated as a foreign corporation and thus would meet the
definition of a "person" under section 7701(a)(1).

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