republic-os/legal/us/code/title-26/chapter-77/section-7525.md

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LegalText	26 U.S.C. § 7525	Confidentiality privileges relating to taxpayer communications	us	united_states_code	code_section	26	INTERNAL REVENUE CODE	77	MISCELLANEOUS PROVISIONS	7525	26 U.S.C. § 7525	current	119-100	2026-06-26	official	https://uscode.house.gov/download/releasepoints/us/pl/119/100/xml_usc26@119-100.zip	/us/usc/t26/s7525	data/legal/raw/us/code/title-26/usc26.xml	2928e22b77dd3b719ea8f116b94b50fbb799323a13a33d195c722f74086137b2	a261f094809116f42a96648a3d5eee80fa010379d67412551c21dd5c900b27f4	e9023a519a3d502c8f1e89e061cae0e4507d74444646bb7006617e138f0545da	2026-07-04	official	legal us-code

26 U.S.C. § 7525 - Confidentiality privileges relating to taxpayer communications

Text

(a) Uniform application to taxpayer communications with federally authorized practitioners (1) General rule With respect to tax advice, the same common law protections of confidentiality which apply to a communication between a taxpayer and an attorney shall also apply to a communication between a taxpayer and any federally authorized tax practitioner to the extent the communication would be considered a privileged communication if it were between a taxpayer and an attorney.

(2) Limitations Paragraph (1) may only be asserted in—

(A) any noncriminal tax matter before the Internal Revenue Service; and

(B) any noncriminal tax proceeding in Federal court brought by or against the United States.

(3) Definitions For purposes of this subsection—

(A) Federally authorized tax practitioner The term “federally authorized tax practitioner” means any individual who is authorized under Federal law to practice before the Internal Revenue Service if such practice is subject to Federal regulation under section 330 of title 31, United States Code.

(B) Tax advice The term “tax advice” means advice given by an individual with respect to a matter which is within the scope of the individual’s authority to practice described in subparagraph (A).

(b) Section not to apply to communications regarding tax shelters The privilege under subsection (a) shall not apply to any written communication which is—

(1) between a federally authorized tax practitioner and—

(A) any person,

(B) any director, officer, employee, agent, or representative of the person, or

(C) any other person holding a capital or profits interest in the person, and

(2) in connection with the promotion of the direct or indirect participation of the person in any tax shelter (as defined in section 6662(d)(2)(C)(ii)).

(Added Pub. L. 105–206, title III, § 3411(a), July 22, 1998, 112 Stat. 750; amended Pub. L. 108–357, title VIII, § 813(a), Oct. 22, 2004, 118 Stat. 1581.)

Notes

Editorial Notes

Amendments2004—Subsec. (b). Pub. L. 108–357 amended heading and text of subsec. (b) generally. Prior to amendment, text read as follows: “The privilege under subsection (a) shall not apply to any written communication between a federally authorized tax practitioner and a director, shareholder, officer, or employee, agent, or representative of a corporation in connection with the promotion of the direct or indirect participation of such corporation in any tax shelter (as defined in section 6662(d)(2)(C)(iii)).”

Statutory Notes and Related Subsidiaries

Effective Date of 2004 AmendmentPub. L. 108–357, title VIII, § 813(b), Oct. 22, 2004, 118 Stat. 1581, provided that: “The amendment made by this section [amending this section] shall apply to communications made on or after the date of the enactment of this Act [Oct. 22, 2004].”

Effective DatePub. L. 105–206, title III, § 3411(c), July 22, 1998, 112 Stat. 751, provided that: “The amendments made by this section [enacting this section] shall apply to communications made on or after the date of the enactment of this Act [July 22, 1998].”