Law Commons^™

Wells Fargo & Co. V. U.S.: A Potential Beginning Of The End Of The Objective Reasonable Basis Tax Penalty Defense, Beckett G. Cantley, Geoffrey C. Dietrich

University of Miami Business Law Review

The Internal Revenue Code (“IRC”) § 6662(a) permits the IRS to impose a twenty-percent (20%) accuracy-related penalty to an underpayment of tax, and there are several different defenses to this penalty depending on the facts of the case and the reason for the penalty.3 One of the most common accuracy-related penalties is the negligence penalty.4 Although there are multiple different reasons for the application of an accuracy-related penalty, only one penalty may be applied for each understatement.5 If a taxpayer faces the negligence penalty, one common defense is that the taxpayer’s return position has a reasonable basis under the relevant …

Shari'a, Financial Institutions' Auditing Manual

UAEU Law Journal

Auditing Islamic, financial institutions by Shari'a is a relatively new industry; thus, there is an urgent need for established rules and theories in order to make it a more stable field. This research shows the extent to which the auditing industry needs to prepare an internal auditing procedure manual.

In the first section of this study, the researcher defines the term "internal auditing procedure." Then, he briefly discusses the legality of auditing and its divisions. In the second section, the researcher draws the parameters of the internal auditing procedure manual; then he mentions the most important procedures that the auditor …

To Innovate Or Regulate: How To Regulate Cloud Service Providers Within Financial Institutions, Morgan Willard

Catholic University Journal of Law and Technology

The purpose of this article is to analyze whether cloud service providers should be considered Systemically Important Financial Market Utilities (SIFMU), subjecting them to increased oversight. It also considers the risks and benefits associated with the use of the technology by financial institutions, as well as potential alternatives. Overall, this article argues that cloud service providers do not fall under the current SIFMU framework, and any regulation of the technology should strive to strike a balance between innovation and safe regulation.