Ezel / IRS Rulings / 201916003

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

Number
201916003
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Confidentiality and Disclosure of Returns and Return Information
Topics
Procedure, penalties, and administration
Code sections
§ 6103
Ruling dated
February 21, 2019
Publicly released
April 19, 2019
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 2019, 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 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 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

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.

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