This definition has been held to include two categories of information: (1) information received by the IRS from a foreign tax administration; and (2) information sent by the IRS to a foreign tax administration provided that the information "relates to and/or reflects on" information it received from the foreign tax administration. See Pacific Fisheries, Inc. v. Internal Revenue Service, No. C04-2436JLR, 2009 WL 1249296, at *4 (W.D. Wash. May 6, 2009), aff'd sub nom. Pacific Fisheries, Inc. v. United States, 395 F.Appx. 438 (9th Cir. 2010).
A district court reviews de novo the IRS's determination that the release of withheld documents would seriously impair federal tax administration. Long v. U.S. Internal Revenue Serv., 742 F.2d 1173, 1182-83 (9th Cir. 1984); Pac. Fisheries, Inc. v. Internal Revenue Serv., No. C04-2436JLR, 2009 WL 1249296, at *3 (W.D.Wash. May 6, 2009). The IRS bears the burden on this issue.