Ezel / IRS Rulings / 201818015

Internet domain names are intangible personal property

Number
201818015
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Types of Property
Topics
Procedure, penalties, and administration
Code sections
§ 6334
Ruling dated
April 16, 2018
Publicly released
May 4, 2018
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 2018, 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 2018
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 confirmed how an internet domain name is classified for federal tax levy purposes. It advised that a domain name is intangible personal property under the provisions governing property exempt from levy. The short email memorialized an earlier discussion and did not address valuation or a specific collection action.

Ruling snapshot

  • Question: Is an internet domain name intangible personal property for purposes of the federal levy exemption rules?
  • Outcome: Advice given: yes.
  • Key authorities: IRC §§ 6334(a)(13)(B)(ii) and 6334(e)(2).

Full text (IRS public release)

ID: CCA_2018041614585720
UILC: 6334.01-00

Number: 201818015
Release Date: 5/4/2018
From:
Sent: Monday, April 16, 2018 2:58:58 PM
To:
Cc:
Bcc:
Subject: internet domain names

Good afternoon.

I apologize—I almost forgot that I said I would send you an email confirming our discussion.

An internet domain name is intangible personal property for the purposes of
6334(e)(2)/6334(a)(13)(B)(ii).

If you would like to discuss this further, please let me know.

What does the Code say today, for your facts?

This advice was written for IRS staff and cannot be cited. Ezel checks the current Internal Revenue Code and IRS guidance against your situation, with citations.

Opens in Ezel Pro.

  • Checks the law as it stands today, not only this page
  • Cites every source it relies on, so you can verify it
  • Chat, drafting and research in one workspace