Pmta-2007-00231
.' . • • • Internal Revenue Service memorandum CC:INTL:BR.l :MEHara CAU-N-I13576-98 date: October 14, 1998 to: John T. Lyons, Assistant Commissioner (International) CP:IN:OO from: W. Edward Williams, Senior Technical Reviewer, Branch I (International) CC:lNTL:Br.l subject: Requestfor Opinion - CIAT Membership ofPuerto Rico In your memorandum dated June 24, 1998, you asked for a formal opinion regarding the matter ofPuerto Rico's request for membership in the Inter-American Center of Tax Administrators (hereafter "CIAT", the organization's Spanish acronym). After reviewing the political status of Puerto Rico, CIAT organizational documents including its Articles of Incorporation,1 Statutes, and Regulations,2 it is our opinion that Puerto Rico does not qualify for CIAT regular membership,3 because the conduct of foreign affairs is assigned by the United States Constitution to the President ofthe United States and Congress, and the political subdivisions of the United States are forbidden from entering into alliances with foreign governments without the explicit authorization of Congress. CIAT (REGULAR) MEMBERSHIP REQUIREMENTS CIAT is an international organization whose purposes include encouraging "bilateral cooperation between members, mainly in an effort to promote voluntary compliance and counteract 1 CIAT was incorporated in Washington D.C., on July 10, 1967, upon the filing of Articles ofIncorporation with the Corporation Division, Office ofRecorder ofDeeds, under the District ofColumbia Non-Profit Corporation Act. The CIAT Articles ofIncorporation names five individuals as the organization's initial directors, including Sheldon S. Cohen, the Col11.ll$sioner ofthe IRS, and the directors ofthe tax authorities ofthe governments of Ecuador, Guatemala, Venezuela and Brazil.
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