Today, the IRS released an Internal Revenue Service Office of Chief Counsel advice memorandum (AM-2015-005) regarding the legal responsibilities to protect tax return information in the context of electronic data transmission through the International Data Exchange Service (IDES).  The memorandum states that outbound information is protected throughout the exchange process under section 6103.  In the case of inbound information, the memorandum states “the moment when legal protection arises is less certain.”  The IRS believes that section 6103 protection arises at the time the information is uploaded to IDES.