Confidentiality and Disclosure of Returns and Return Information

ID:
UILC:
CCA_2016020909094307
6103.00-00
[Third Party Communication:
Date of Communication: Month DD, YYYY]
Number: 201608015
Release Date: 2/19/2016
From:
Sent: Tuesday, February 09, 2016 9:09:43 AM
To:
Cc:
Bcc:
Subject: RE: Disclosure question
Then you should continue to deal with the plan sponsor. For the LLC as a plan sponsor, you can deal with anyone who has authority under state law to act/bind the LLC. The plan sponsor is the LLC so you have to deal with the LLC and then it’s just whoever has authority to act on behalf of the LLC. The TEFRA part is sort of a red herring. You aren’t auditing the LLC and you aren’t disclosing the LLC’s return information so TEFRA doesn’t really come into play. If you need to contact someone other than someone who has authority under state law to act for the LLC, then 6103(k)(6) may authorize the disclosure.
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