Chief Counsel Advice 202118011 Released May 7, 2021 Advice

Additional nondisclosure language accepted

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This page covers one taxpayer's ruling from 2021, which can't be cited as precedent. Ezel answers your situation under the current Code and IRS guidance, with citations.

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.
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Plain-English summary

This brief Chief Counsel email reviews additional language for a nondisclosure agreement. The writer states that the language looked good and planned to contact a redacted party again. The writer also noted uncertainty about how extensively that party reviewed agreements of this kind. The public release contains no agreement text or further legal analysis.

Ruling snapshot

  • Question: Was the additional nondisclosure-agreement language acceptable?
  • Outcome: Advice given: yes.
  • Key authorities: UILC 6103.14-00, disclosure to contractors

Full text (IRS public release)

ID: CCA_2020021313435143
UILC: 6103.14-00

Number: 202118011
Release Date: 5/7/2021
From:
Sent: Thursday, February 13, 2020 1:43:51 PM
To:
Cc:
Bcc:
Subject: RE: NDA

The additional language looks good to me. I will reach out again to -----------------------. I
really don’t know to what extent they review these types of agreements.

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