§6105 Confidentiality of Information Arising Under Treaty Obligations

Summary

Keeps information shared under tax treaties secret. It can only be shared in four situations: when the treaty lets certain people or authorities (like courts) see it; under general rules about asking for treaty relief; the same way tax return information can be shared under 6103(i)(3)(C) or (7) — but if a foreign government gave the information, that government must give written permission; or when the information is not about a specific taxpayer and the Secretary, after talking with the other treaty parties, decides sharing won’t harm tax administration. Definitions: "Tax convention information" means treaty agreements, relief applications, related background and implementing documents, and other exchanged items labeled confidential. "Tax convention" means tax treaties or agreements that avoid double taxation, prevent tax evasion, address nondiscrimination, exchange tax information, or provide mutual tax help. Unauthorized disclosure that is also return information can be punished under sections 7213, 7213A, and 7431.