Chief Counsel Advice 201443018 Released October 24, 2014 Advice

Limit SharePoint access to protected taxpayer information

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This page covers one taxpayer's ruling from 2014, 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 2014
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 advised that training materials, legal advice, and white papers created by field attorneys and agents could be placed on SharePoint if the National Office had not reviewed them. Documents containing tax returns or return information must be limited to Counsel attorneys and IRS employees with a need to know under IRC § 6103(h)(1). The reviewer did not see protected information already posted. If such information might be added, access should be restricted to personnel assigned to marijuana business cases.

Ruling snapshot

  • Question: What access controls apply when field-created materials and possible return information are placed on an IRS SharePoint site?
  • Outcome: Advice given
  • Key authorities: IRC § 6103(h)(1)

Full text (IRS public release)

ID: CCA_2014092914365506 [Third Party Communication:

UILC: 6110.02-00 Date of Communication: Month DD, YYYY]

Number: 201443018
Release Date: 10/24/2014
From:
Sent: Monday, September 29, 2014 2:36:55 PM
To:
Cc:
Bcc:
Subject: RE: Request for Advice from -------- Sharepoint/Disclosure/Privilege Issues

--------If the training materials, legal advice, and whitepapers are created by field
attorneys and field agents (and not reviewed by the National Office), then the
documents may be placed on SharePoint. Any documents that contain returns or return
information should only be available to Counsel attorneys and IRS employees on a
“need to know” basis. See I.R.C. § 6103(h)(1). While I did not notice any returns or
return information currently posted to your SharePoint, if returns or return information
may be placed on the SharePoint, then I suggest limiting access to the Sharepoint to
only those Counsel and IRS employees that are assigned to marijuana business cases.
Let me know if you would like to discuss this further.

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