Ezel / IRS Rulings / 1138038
Chief Counsel Advice 1138038 Released September 23, 2011 Advice

CCA 1138038: Foreign professional contacting a U.S. revenue officer is representing in the United States

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This page covers one taxpayer's ruling from 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 resolved one taxpayer's situation on its specific facts, 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 where representation occurs when a foreign attorney or accountant contacts an IRS revenue officer in the United States. The advice stated that the representation is not occurring outside the United States in that situation. The release refers to prior advice but does not reproduce its underlying analysis.

Ruling snapshot

  • Question: Does representation occur outside the United States when a foreign attorney or accountant contacts a U.S.-based revenue officer?
  • Outcome: advice given
  • Key authorities: Prior Chief Counsel Advice identified in the release as CCA-628390-10, No. 201105041

Full text (IRS public release)

ID: CCA_2011072510033853 Number: 201138038
Release Date: 9/23/2011
Office: ----------------------------
UILC: 9999.00-00

From: --------------------
Sent: Monday, July 25, 2011 10:03:49 AM
To: ----------------------
Cc:
Subject: Representation question

Hi ------------

Attached is the prior advice I mentioned on the phone. Note: When a foreign attorney or accountant
located in a foreign country contacts a revenue officer located in the United States, the representation is
not occurring outside the United States.

Please feel free to contact me if you have any additional questions.

Thank you,

Attachment: CCA-628390-10 No. 201105041

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