Browse Arkansas Code titles and sections
26 U.S.C. § 6105 — Confidentiality of information arising under treaty obligations
Federal law — U.S. Code and appendices · legal_authorities
**(a) In general** Tax convention information shall not be disclosed.
**(b) Exceptions** Subsection (a) shall not apply—
(1) to the disclosure of tax convention information to persons or authorities (including courts and administrative bodies) which are entitled to such disclosure pursuant to a tax convention,
(2) to any generally applicable procedural rules regarding applications for relief under a tax convention,
(3) to the disclosure of tax convention information on the same terms as return information may be disclosed under paragraph (3)(C) or (7) of section 6103(i), except that in the case of tax convention information provided by a foreign government, no disclosure may be made under this paragraph without the written consent of the foreign government, or
(4) in any case not described in paragraph (1), (2), or (3), to the disclosure of any tax convention information not relating to a particular taxpayer if the Secretary determines, after consultation with each other party to the tax convention, that such disclosure would not impair tax administration.
**(c) Definitions** For purposes of this section—
(1) **Tax convention information** — The term “tax convention information” means any—
(A) agreement entered into with the competent authority of one or more foreign governments pursuant to a tax convention,
(B) application for relief under a tax convention,
(C) background information related to such agreement or application,
(D) document implementing such agreement, and
(E) other information exchanged pursuant to a tax convention which is treated as confidential or secret under the tax convention.
(2) **Tax convention** — The term “tax convention” means—
(A) any income tax or gift and estate tax convention, or
(B) any other convention or bi
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 6105
Stored review status: release_metadata_unconfirmed. A text match is a research starting point; applicability is not established.
Original supplied file — preserved unchanged
Download original Markdown file
File SHA-256: 288edfe76d76d43bc78b7dab2a7de926816631281fdd7a5278bcdbd40d66e05a. The original may include catalog metadata, neighboring provisions, or embedded records outside this collection's scope. Search shows only the selected federal record. Historical editions and unverified snapshots are not a statement of current law.
Authority boundary: historical or unconfirmed source not current law verified.
Open the recorded source website ↗
Record provenance
Stable record: federal_law:legal_authorities:record_usc_cd9bd4649513d997772383e6
Source file: Laws/federal/codes/united-states-code/title-26/section-6105-confidentiality-of-information-arising-under-treaty-obligations--3387ce4055.md
Pages: Not recorded – Not recorded
Passage SHA-256: be8dcef197741d9db225e0e7d94f36f266f637c0972ed80fd1ccba510fe73fb4
Source location: Title 26, Chapter 61, § 6105; chapter-061-information-and-returns.md
Stored source content
**(a) In general** Tax convention information shall not be disclosed.
**(b) Exceptions** Subsection (a) shall not apply—
(1) to the disclosure of tax convention information to persons or authorities (including courts and administrative bodies) which are entitled to such disclosure pursuant to a tax convention,
(2) to any generally applicable procedural rules regarding applications for relief under a tax convention,
(3) to the disclosure of tax convention information on the same terms as return information may be disclosed under paragraph (3)(C) or (7) of section 6103(i), except that in the case of tax convention information provided by a foreign government, no disclosure may be made under this paragraph without the written consent of the foreign government, or
(4) in any case not described in paragraph (1), (2), or (3), to the disclosure of any tax convention information not relating to a particular taxpayer if the Secretary determines, after consultation with each other party to the tax convention, that such disclosure would not impair tax administration.
**(c) Definitions** For purposes of this section—
(1) **Tax convention information** — The term “tax convention information” means any—
(A) agreement entered into with the competent authority of one or more foreign governments pursuant to a tax convention,
(B) application for relief under a tax convention,
(C) background information related to such agreement or application,
(D) document implementing such agreement, and
(E) other information exchanged pursuant to a tax convention which is treated as confidential or secret under the tax convention.
(2) **Tax convention** — The term “tax convention” means—
(A) any income tax or gift and estate tax convention, or
(B) any other convention or bilateral agreement (including multilateral conventions and agreements and any agreement with a possession of the United States) providing for the avoidance of double taxation, the prevention of fiscal evasion, nondiscrimination with respect to taxes, the exchange of tax relevant information with the United States, or mutual assistance in tax matters.
**(d) Cross references** For penalties for the unauthorized disclosure of tax convention information which is return or return information, see sections 7213, 7213A, and 7431.
Cross-references
Connections may be documented source relationships, shared citations or nearby passages. Each explains its basis; a connection alone does not establish applicability to your situation.
Federal law — U.S. Code and appendices · legal_authorities
**(a) General rule** Returns and return information shall be confidential, and except as authorized by this title—
(1) no officer or employee of the United States,
(2) no officer or employee of any State, any local law enforcement agency receiving information under subsection (i)(1)(C) or (7)(A), any tribal or local child support enforcement agency, or any local agency administering a program listed in subsection (l)(7)(D) who has or had access to returns or return information under this section or section 6104(c), and
(3) no other person (or officer or employee thereof) who has or had access to returns or return information under subsection (c), subsection (e)(1)(D)(iii), paragraph (10), (13), (14), or (15) of subsection (k), paragraph (6), (8), (10), (12), (13) (other than subparagraphs (D)(v) and (D)(vi) thereof), (16), (19), (20), or (21) of subsection (l), paragraph (2) or (4)(B) of subsection (m), or subsection (n),
shall disclose any return or return information obtained by him in any manner in connection with his service as such an officer or an employee or otherwise or under the provisions of this section. For purposes of this subsection, the term “officer or employee” includes a former officer or employee.
**(b) Definitions** For purposes of this section—
(1) **Return** — The term “return” means any tax or information return, declaration of estimated tax, or claim for refund required by, or provided for or permitted under, the provisions of this title which is filed with the Secretary by, on behalf of, or with respect to any person, and any amendment or supplement thereto, including supporting schedules, attachments, or lists which are supplemental to, or part of, the return so filed.
(2) **Return information** — The term “return information” means—
(
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 6103
Stored review status: release_metadata_unconfirmed. Explicit cross-reference supplied in source Markdown; currentness and applicability require review.
Federal law — U.S. Code and appendices · legal_authorities
**(a) General rule** Except as otherwise provided in this section, the text of any written determination and any background file document relating to such written determination shall be open to public inspection at such place as the Secretary may by regulations prescribe.
**(b) Definitions** For purposes of this section—
(1) **Written determination**
(A) *In general* — The term “written determination” means a ruling, determination letter, technical advice memorandum, or Chief Counsel advice.
(B) *Exceptions* — Such term shall not include any matter referred to in subparagraph (C) or (D) of section 6103(b)(2).
(2) **Background file document** — The term “background file document” with respect to a written determination includes the request for that written determination, any written material submitted in support of the request, and any communication (written or otherwise) between the Internal Revenue Service and persons outside the Internal Revenue Service in connection with such written determination (other than any communication between the Department of Justice and the Internal Revenue Service relating to a pending civil or criminal case or investigation) received before issuance of the written determination.
(3) **Reference and general written determinations**
(A) *Reference written determination* — The term “reference written determination” means any written determination which has been determined by the Secretary to have significant reference value.
(B) *General written determination* — The term “general written determination” means any written determination other than a reference written determination.
**(c) Exemptions from disclosure** Before making any written determination or background file document open or available to public inspection under
Source: Supplied U.S. Code snapshot — release unconfirmed · 26 U.S.C. § 6110
Stored review status: release_metadata_unconfirmed. Incoming connection: Explicit cross-reference supplied in source Markdown; currentness and applicability require review.
Federal law — U.S. Code and appendices · legal_authorities
Page 3479
TITLE 26—INTERNAL REVENUE CODE
§ 6105
the regulations referred to section 6104(e)(3) of the In-
ternal Revenue Code of 1986 (as added by subsection
(a)(3)).’’
EFFECTIVE DATE OF 1987 AMENDMENT
Pub. L. 100–203, title X, § 10702(b), Dec. 22, 1987, 101
Stat. 1330–460, provided that: ‘‘The amendment made by
subsection (a) [amending this section] shall apply—
‘‘(1) to returns for years beginning after December
31, 1986, and
‘‘(2) on and after the 30th day after the date of the
enactment of this Act [Dec. 22, 1987] in the case of ap-
plications submitted to the Internal Revenue Serv-
ice—
‘‘(A) after July 15, 1987, or
‘‘(B) on or before July 15, 1987, if the organization
has a copy of the application on July 15, 1987.’’
EFFECTIVE DATE OF 1984 AMENDMENT
Amendment by section 306(b) of Pub. L. 98–369 effec-
tive Jan. 1, 1985, see section 306(c) of Pub. L. 98–369, set
out as a note under section 4946 of this title.
Amendment by section 491(d)(49) of Pub. L. 98–369 ap-
plicable to obligations issued after Dec. 31, 1983, see sec-
tion 491(f)(1) of Pub. L. 98–369, set out as a note under
section 62 of this title.
EFFECTIVE DATE OF 1980 AMENDMENT
Amendment by Pub. L. 96–603 applicable to taxable
years beginning after Dec. 31, 1980, see section 1(f) of
Pub. L. 96–603, set out as a note under section 6033 of
this title.
EFFECTIVE DATE OF 1978 AMENDMENTS
Amendment by Pub. L. 95–600 effective Oct. 4, 1976,
see section 703(r) of Pub. L. 95–600, set out as a note
under section 46 of this title.
Amendment by Pub. L. 95–488 effective with respect
to taxable years beginning after Dec. 31, 1977, and noth-
ing in amendment by Pub. L. 95–488 construed to per-
mit disclosure of confidential business information of
contributors to any trust described in section 50
Source: Supplied 2024 U.S. Code historical extraction · 26 U.S.C. § 6105
Stored review status: historical_2024_not_currentness_verified. Same stored citation; legal effect and authority still require review.