Ezel / IRS Rulings / 201319016

CCA 201319016: IRS enforcement authority applies in Puerto Rico

Number
201319016
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Administration and Collection of Taxes in Possessions
Topics
Procedure, penalties, and administration
Code sections
§ 7651
Ruling dated
January 25, 2013
Publicly released
May 10, 2013
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 2013, 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 2013
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 states that IRC § 7651 gives the IRS authority to apply the Code's enforcement provisions in Puerto Rico. It separately states that the Dominican Republic is a foreign country and that the IRS generally has no authority to issue a summons there, subject to the referenced tax information exchange agreement.

Ruling snapshot

  • Question: Where may the IRS apply the Code's enforcement provisions and issue a summons?
  • Outcome: Advice given.
  • Key authorities: IRC § 7651; tax information exchange agreement referenced in the release

Full text (IRS public release)

1

ID: CCA-12930-13 Number: 201319016
Release Date: 5/10/2013
Office: ------------
UILC: 7651.00-00

From: -------------------------
Sent: Friday, January 25, 2013 9:28 AM
To: -----------------
Cc: ----------------------------
Subject: Puerto Rico

------Yes under section 7651 there is authority for the IRS to apply the enforcement provisions of the Code
in Puerto Rico.

The Dominican Republic is a foreign country and generally there is no authority for the IRS to issue a
summons in DR --see attached TIEA.

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