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Internal Revenue Service Summonses For "Sensitive"Accountants' Papers, Robert G. Nath
Internal Revenue Service Summonses For "Sensitive"Accountants' Papers, Robert G. Nath
Vanderbilt Law Review
Every modern public corporation has obligations of accountability and disclosure to the public and to its shareholders. These accepted duties of disclosure, however, become the source of conflicts when government agencies make unanticipated inquiries of accountants about otherwise private or background data concerning the corporations they audit. This is particularly true when a public corporation's duties of financial accountability, which stem chiefly from securities law requirements and fiduciary duties,evoke the Internal Revenue Service's interest in information that may reveal or be probative of the corporation's tax liability. Most corporate taxpayers and their accountants understand and accept--if only reluctantly--their obligations to …
Comparative Analysis Of Systems Of Domestic Taxation Of Controlled Foreign Corporations, Jamie S. Martin, A. Dale Wilson
Comparative Analysis Of Systems Of Domestic Taxation Of Controlled Foreign Corporations, Jamie S. Martin, A. Dale Wilson
Vanderbilt Journal of Transnational Law
This Note outlines the existing law and practice of the domestic taxation of CFC's in the United States, United Kingdom, France, West Germany, and Japan, each of which exhibits a high level of economic and industrial advancement. United States developments are important because the statutory provisions of Subpart F have been adopted, with modifications, by other nations, including West Germany and Japan. The United Kingdom and France, on the other hand, have not yet adopted an integrated statutory scheme providing for domestic taxation of CFC's. These countries attack tax evasion schemes utilizing foreign controlled companies primarily through general laws, exchange …