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Internal Revenue Service Memorandum

Office of Chief CounselInternal Revenue ServiceMemorandumNumber: AM2016-004 Release Date: 10/14/2016CC:INTL:MARollinsonPOSTU-10380 1-16 , : June 17, 2016to: John M. DalrympleDeputy Commissioner for services and Enforcementfrom: Marjorie A. RollinsonAssociate Chief Counsel(International) subject:OECD COMMON TRANSMISSION SYSTEM (CTS) --RESPONSIBILTY FOR DATA TRANSMITTED UNDER SECTION 6103 AND 6105, AND TAX TREATIESThe Commissioner requested written advice regarding the issue of when legal responsibilities to protect tax return information arise in the context of electronic data transmission through the Common Transmission System (CTS). The CTS is a global transmission system being developed under the Organization for Economic Cooperation and Development (OECD) forum on Tax administration (FTA).

1The FTA is a forum on tax administration for Commissioners from 46 OECD and non-OECD countries, including every member of the G20. Some of the primary purposes of the FTA are to create a forum through which

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