Ezel / IRS Rulings / 201916003
Chief Counsel Advice 201916003 Released April 19, 2019 Advice

Information gathered from a foreign financial institution can be a taxpayer's return information

Apply this to your situation

This page covers one taxpayer's ruling from 2019, which can't be cited as precedent. Ezel answers your situation under the current Code and IRS guidance, with citations.

Currency note: this determination was released in 2019
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

This short Chief Counsel email answers whether information the IRS obtained from a foreign financial institution (FFI) is protected as a taxpayer's "return information" under section 6103. The advice states that if the IRS gathered the information from the FFI as part of a determination of the taxpayer's liability or possible liability, then it is the return information of that taxpayer under section 6103, and therefore subject to the confidentiality and disclosure limits of that section. The message is a concise, fact-dependent conclusion rather than a full analysis.

Ruling snapshot

  • Question: Is information the IRS obtained from a foreign financial institution the taxpayer's return information under section 6103?
  • Outcome: advice (yes, if gathered as part of a determination of the taxpayer's liability or possible liability)
  • Key authorities: IRC § 6103

Full text (IRS public release)

ID:          CCA_2019022114170343
UILC:        6103.02-00

Number: 201916003
Release Date: 4/19/2019
From:
Sent: Thursday, February 21, 2019 2:17:03 PM
To:
Cc:
Bcc:
Subject: RE: Review assistance needed - DISSP-102446-19

If the IRS gathered the information from the FFI as part of a determination of liability or
possible liability of the taxpayer, it is the return information of the taxpayer under section
6103.

----------------
----------------------
--------------
--------------------------------

Get today's answer for your situation

You just read what the IRS ruled for one taxpayer in 2019, and it can't be cited as precedent. Ezel checks the current Internal Revenue Code and IRS guidance and answers your specific situation, with citations.

Opens in Ezel Pro. Every answer cites the authority it relies on.