Rev. Rul. 2022-7: Federal, state, and local government employees also subject to disclosure restrictions regarding returns

Determining when government employees who receive returns or return information are subject to the disclosure restrictions

Government employees subject to disclosure restrictions regarding returns

The IRS today released an advance version of Rev. Rul. 2022-7 that concludes that all recipients of returns or return information pursuant to section 6103(c), including government employees, are subject to the disclosure restrictions of section 6103(a). Thus, government employees who receive returns or return information pursuant to disclosures under section 6103(c)—like all designees who receive returns or return information pursuant to taxpayer consent—are subject to the disclosure restrictions of section 6103(a). 

Rev. Rul. 2022-7 [PDF 114 KB] examines seven factual situations and notes that government employees who receive returns or return information pursuant to disclosures under section 6103(k)(6) or (e) (other than section 6103(e)(1)(D)(iii) (relating to certain shareholders)) are not subject to the disclosure restrictions of section 6103(a) with regard to the returns or return information received.

 

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