Ezel / IRS Rulings / 201125018

CCA 201125018: No automatic reporting requirement was identified

Number
201125018
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Miscellaneous Issues
Topics
Other topics
Code sections
§ 9999
Ruling dated
April 26, 2011
Publicly released
June 24, 2011
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 2011, 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 2011
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 whether there was an automatic reporting requirement for information concerning an individual. The advice stated that it was not aware of an automatic requirement, although a foreign government might request the information through an exchange-of-information request. It added that a United States payor would generally report wages on Form W-2 if the individual is treated as an employee. The release identifies no Internal Revenue Code section beyond UILC 9999.00-00.

Ruling snapshot

  • Question: Is there an automatic reporting requirement for the information at issue?
  • Outcome: Advice given.
  • Key authorities: The release identifies no Internal Revenue Code section beyond UILC 9999.00-00; Form W-2 reporting is mentioned for employees.

Full text (IRS public release)

ID: CCA_2011042611572652 Number: 201125018
Release Date: 6/24/2011
Office: ------------------
UILC: 9999.00-00

From: -------------------
Sent: Tuesday, April 26, 2011 11:57:34 AM
To: -----------------------
Cc:
Subject: RE: another question...

There is no automatic reporting requirement that I'm aware of, although, I suppose, a foreign government
may ask for that information under an exchange of information request. Generally, the US payor would
report wages on Form W-2 if the individual is treated as an employee.

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