Publication 4639 Catalog Number 50891P (Rev

Total Page:16

File Type:pdf, Size:1020Kb

Publication 4639 Catalog Number 50891P (Rev Chief Counsel PROCEDURE & ADMINISTRATION Publication 4639 Catalog Number 50891P (Rev. 10-2012) Department of the Treasury Internal Revenue Service www.irs.gov TABLE OF CONTENTS To the Reader:................................................................................................................ iii CHAPTER 1 ................................................................................................................ 1-1 PART I: HISTORY AND OVERVIEW – I.R.C. § 6103 ........................................... 1-1 PART II: CIVIL DAMAGES FOR UNAUTHORIZED INSPECTION AND DISCLOSURE I.R.C. § 7431................................................................ 1-19 PART III: CRIMINAL LIABILITY FOR WILLFUL UNAUTHORIZED INSPECTION AND DISCLOSURE....................................................... 1-48 CHAPTER 2 ................................................................................................................ 2-1 PART I: DEFINITIONS .......................................................................................... 2-1 PART II: DISCLOSURES TO PERSONS WITH A MATERIAL INTEREST I.R.C. § 6103(e) ................................................................... 2-9 PART III: DISCLOSURES PURSUANT TO TAXPAYER'S CONSENT I.R.C. § 6103(c) .................................................................................... 2-19 PART IV: DISCLOSURE OF INFORMATION AVAILABLE IN THE PUBLIC RECORD................................................................................ 2-28 PART V: DISCLOSURES TO COMMITTEES OF CONGRESS I.R.C. § 6103(f)..................................................................................... 2-33 PART VI: DISCLOSURES TO PRESIDENT AND CERTAIN OTHER PERSONS I.R.C. § 6103(g).................................................... 2-35 CHAPTER 3 TAX ADMINISTRATION DISCLOSURES I.R.C. § 6103(h).................... 3-1 CHAPTER 4 TAX ADMINISTRATION INVESTIGATIVE DISCLOSURES AND DISCLOSURES TO CONTRACTORS I.R.C. § 6103(k)(6) AND (n) ................. 4-1 CHAPTER 5 DISCLOSURES FOR NONTAX CRIMINAL PURPOSES I.R.C. § 6103(i).................................................................................................. 5-1 CHAPTER 6 DISCLOSURE OF RETURNS AND RETURN INFORMATION IN BANKRUPTCY CASES .................................................................................... 6-1 CHAPTER 7 BANK SECRECY ACT, MONEY LAUNDERING, FORFEITURE AND RETURN INFORMATION......................................................................... 7-1 CHAPTER 8 FEDERAL/STATE EXCHANGE PROGRAM I.R.C. ' 6103(d) AND (p)(8)......................................................................................................... 8-1 CHAPTER 9 FREEDOM OF INFORMATION ACT ..................................................... 9-1 i CHAPTER 10 LITIGATION PRIVILEGES ................................................................. 10-1 CHAPTER 11 ............................................................................................................ 11-1 PART I: PERSONNEL AND CLAIMANT REPRESENTATIVE MATTERS I.R.C. § 6103(l)(4)................................................................................. 11-1 PART II: PRIVACY ACT...................................................................................... 11-5 CHAPTER 12 TESTIMONY AUTHORIZATION ........................................................ 12-1 CHAPTER 13 ............................................................................................................ 13-1 PART I: PUBLIC INSPECTION OF WRITTEN DETERMINATIONS I.R.C. § 6110 ........................................................................................ 13-1 PART II: CONFIDENTIALITY OF INFORMATION ARISING UNDER TREATY OBLIGATIONS – I.R.C. § 6105........................................... 13-13 PART III: PUBLICITY OF INFORMATION REQUIRED FROM CERTAIN EXEMPT ORGANIZATIONS – I.R.C. § 6104 .................... 13-16 CHAPTER 14 DISCLOSURE GUIDE FOR TAX-EXEMPT BOND EXAMINATIONS.................................................................................. 14-1 CHAPTER 15 APPENDICES .................................................................................... 15-1 APPENDIX-1 CONSENT TO DISCLOSURE OF TAX INFORMATION .............. 15-2 APPENDIX-2 CONSENT TO DISCLOSURE OF RETURN INFORMATION....... 15-4 APPENDIX-3 TESTIMONY REPORT AND AUTHORIZATION........................... 15-6 APPENDIX-4 POWER OF ATTORNEY AND DECLARATION OF REPRESENTATIVE ............................................................................. 15-8 APPENDIX-5 TAX INFORMATION AUTHORIZATION..................................... 15-10 APPENDIX-6 TAX DISCLOSURES .................................................................. 15-14 APPENDIX-7 CURRENT IRS EMPLOYEE TESTIMONY AUTHORIZATION... 15-16 APPENDIX-8 FORMER IRS EMPLOYEE TESTIMONY AUTHORIZATION..... 15-18 APPENDIX-9 BOND EXAMINATION - CONSENTS ......................................... 15-20 APPENDIX-10 LINKS........................................................................................ 15-22 ii To the Reader: This reference guide updates and replaces the Disclosure Litigation and Reference Book last revised in 2011. It covers the primary disclosure laws that affect the Internal Revenue Service (I.R.C. §§ 6103 and 6110, the Freedom of Information Act (FOIA), and the Privacy Act of 1974), related statutes, and testimony authorization procedures. Together, these laws represent efforts by the Congress to strike a balance between a citizen’s expectation of privacy and an open and effective government. Guidance on legal matters concerning these disclosure laws is provided by the Office of the Associate Chief Counsel (Procedure & Administration). This office is also responsible for defending litigation filed pursuant to I.R.C. §§ 6103 and 6110, FOIA, and the Privacy Act. Electronic distribution of judicial opinions has provided wide access to decisions that the issuing courts did not view as important or precedential. Although this guide cites to "unpublished" cases by reference to the federal reporter’s table citation followed by an applicable electronic or specialized reporter citation number, court rules often instruct that decisions a court has affirmatively designated not to be published should not be cited at all or only under severely limited circumstances. They are included in this guide to elucidate the courts’ reasoning on the various legal issues outlined herein for which there is a relatively sparse body of case law. Before you cite a decision that the deciding court has labeled "unpublished" or "non-precedential" you should consult that court's rules on this point. We have not cited to multiple reporters when there is more than one source for an opinion, but the default preference for electronically available opinions is Westlaw. Obviously, correct legal advice concerning the matters addressed in this guide depends upon the facts of each question. This guide was prepared for reference purposes only; it may not be used or cited as authority for setting or sustaining a legal position. iii CHAPTER 1 PART I: HISTORY AND OVERVIEW – I.R.C. § 6103 I. HISTORY OF TAX CONFIDENTIALITY LAWS1 A. Introduction Except for a few periods in our history, taxpayers’ tax information generally has not been available to the public – disclosure has been restricted. Congress has used two basic approaches in determining whether, and under what circumstances, tax information could be disclosed. Under the first approach, taken prior to 1977, tax information was considered a "public record," but was only open to inspection under Treasury regulations approved by the President or under presidential order. Under this scheme, the Executive Branch essentially created all the rules regarding disclosure. By the mid 1970s, there was increased congressional and public concern about the widespread use of tax information by government agencies for purposes unrelated to tax administration. This concern culminated with the enactment of section 6103, passed as part of the Tax Reform Act of 1976. Pub. L. No. 94-455, 90 Stat. 1520 (1976) (Tax Reform Act codified at scattered sections of 7, 26, and 46 U.S.C.). There, Congress eliminated much of the executive discretion concerning the disclosure of returns or return information. With this second approach, Congress established a new statutory scheme under which returns and return information are confidential and not subject to disclosure except to the extent explicitly provided by the Internal Revenue Code. Although there have been many amendments to the law since that time, the basic statutory scheme established in 1976 remains in place today. B. Publicity of Tax Returns The history of tax information confidentiality may be traced to the Civil War Income Tax Act of 1862,2 when tax information was posted on courthouse doors 1 Much of the information in this chapter was taken from Report on Administrative Procedures of the Internal Revenue Service, S. Doc. No. 94-266, at 821-1028 (1975); HOWARD M. ZARITSKY, CONG. RESEARCH SERV., 74- 211A, LEGISLATIVE HISTORY OF TAX RETURN CONFIDENTIALITY: SECTION 6103 OF THE INTERNAL REVENUE CODE OF 1954 AND ITS PREDECESSORS (1974); Richard F. Janssen, Income Tax Snooping Through History, WALL ST. J., May 6, 1970, at 18; and Mitchell Rogovin, Privacy and Income Tax Returns, WASH.POST, Oct. 13, 1974, at C4. 2 Act of July 1, 1862, ch. 109, 12 Stat. 432, 437. Ambiguities in that provision regarding public inspection led Congress, in 1864, to explicitly permit public inspection of the assessment list:
Recommended publications
  • A Brief Description of Federal Taxes
    A BRIEF DESCRIFTION OF FEDERAL TAXES ON CORPORATIONS SINCE i86i WMUAu A. SU. ND* The cost to the federal government of financing the Civil War created a need for increased revenue, and Congress in seeking new sources tapped theretofore un- touched corporate and individual profits. The Act of July x, x862, amending the Act of August 5, x86i, is the first law under which any federal income tax was collected and is considered to be largely the basis of our present system of income taxation. The tax acts of the Civil War period contained provisions imposing graduated taxes upon the gain, profits, or income of every person2 and providing that corporate profits, whether divided or not, should be taxed to the stockholders. Certain specified corporations, such as banks, insurance companies and transportation companies, were taxed at the rate of 5%, and their stockholders were not required to include in income their pro rata share of the profits. There were several tax acts during and following the War, but a description of the Act of 1864 will serve to show the general extent of the coiporate taxes of that period. The tax or "duty" was imposed upon all persons at the rate of 5% of the amount of gains, profits and income in excess of $6oo and not in excess of $5,000, 7Y2/ of the amount in excess of $5,ooo and not in excess of -$o,ooo, and io% of the amount in excess of $Sxooo.O This tax was continued through the year x87i, but in the last two years of its existence was reduced to 2/l% upon all income.
    [Show full text]
  • BEYOND PUBLIC CHOICE and PUBLIC INTEREST: a STUDY of the LEGISLATIVE PROCESS AS ILLUSTRATED by TAX LEGISLATION in the 1980S
    University of Pennsylvania Law Review FOUNDED 1852 Formerly American Law Register VOL. 139 NOVEMBER 1990 No. 1 ARTICLES BEYOND PUBLIC CHOICE AND PUBLIC INTEREST: A STUDY OF THE LEGISLATIVE PROCESS AS ILLUSTRATED BY TAX LEGISLATION IN THE 1980s DANIEL SHAVIRO" TABLE OF CONTENTS I. INTRODUCTION ................................. 3 II. HISTORICAL OVERVIEW OF CYCLICAL TAX LEGISLATION ... 11 A. Legislation From the Beginning of the Income Tax Through the 1970s: The Evolution of Tax Instrumentalism and Tax Reform ..................................... 11 t Assistant Professor, University of Chicago Law School. The author was a Legislation Attorney with theJoint Committee of Taxation during the enactment of the 1986 tax bill discussed in this Article. He is grateful to Walter Blum, Richard Posner, Cass Sunstein, and the participants in a Harvard Law School seminar on Current Research in Taxation, held in Chatham, Massachusetts on August 23-26, 1990, for helpful comments on earlier drafts, to Joanne Fay and Michael Bonarti for research assistance, and to the WalterJ. Blum Faculty Research Fund and the Kirkland & Ellis Faculty Fund for financial support. 2 UNIVERSITY OF PENNSYLVANIA LAW REVIEW [Vol. 139: 1 B. The 1981 Act and Its Aftermath ................... 19 C. The 1986 Act ............................... 23 D. Aftermath of the 198.6 Act ......................... 29 E. Summary .................................. 30 III. THE PUBLIC INTEREST THEORY OF LEGISLATION ........ 31 A. The Various Strands of Public Interest Theory .......... 31 1. Public Interest Theory in Economics ............ 31 2. The Pluralist School in Political Science .......... 33 3. Ideological Views of the Public Interest .......... 35 B. Criticisms of PublicInterest Theory .................. 36 1. (Largely Theoretical) Criticisms by Economists ... 36 a. When Everyone "Wins," Everyone May Lose ..
    [Show full text]
  • Ways and Means Committee's Request for the Former President's
    (Slip Opinion) Ways and Means Committee’s Request for the Former President’s Tax Returns and Related Tax Information Pursuant to 26 U.S.C. § 6103(f )(1) Section 6103(f )(1) of title 26, U.S. Code, vests the congressional tax committees with a broad right to receive tax information from the Department of the Treasury. It embod- ies a long-standing judgment of the political branches that the tax committees are uniquely suited to receive such information. The committees, however, cannot compel the Executive Branch to disclose such information without satisfying the constitutional requirement that the information could serve a legitimate legislative purpose. In assessing whether requested information could serve a legitimate legislative purpose, the Executive Branch must give due weight to Congress’s status as a co-equal branch of government. Like courts, therefore, Executive Branch officials must apply a pre- sumption that Legislative Branch officials act in good faith and in furtherance of legit- imate objectives. When one of the congressional tax committees requests tax information pursuant to section 6103(f )(1), and has invoked facially valid reasons for its request, the Executive Branch should conclude that the request lacks a legitimate legislative purpose only in exceptional circumstances. The Chairman of the House Ways and Means Committee has invoked sufficient reasons for requesting the former President’s tax information. Under section 6103(f )(1), Treasury must furnish the information to the Committee. July 30, 2021 MEMORANDUM OPINION FOR THE ACTING GENERAL COUNSEL DEPARTMENT OF THE TREASURY The Internal Revenue Code requires the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”) to keep tax returns and related information confidential, 26 U.S.C.
    [Show full text]
  • Federal Income Tax Returns--Confidentiality Vs
    Federal Income Tax Returns--Confidentiality vs. Public Disclosure* by Boris I. Bittker* * I. INTRODUCTION This article will examine the relationship between the individual's interest in privacy, reflected in such recent statutes as the Privacy Act of 1974, I and the public's right to know, which underlies legislation like the Freedom of Information Act. 2 The subject is of intrinsic impor­ tance, but it is particularly appropriate for an article in this lecture se­ ries, since privacy3 and disclosure4 were values of special interest to Justice Douglas. Neither the individual's right to privacy5 nor the pub­ lic's right to know6 is explicitly protected by the Constitution, but both do have constitutional overtones, and both are protected by various statutory provisions. Using federal income tax returns as the centerpiece of the discus­ sion, I propose to show how privacy and disclosure can come into con­ flict-a possibility that has been insufficiently recognized by the courts and the commentators. The leading treatise on political and civil rights,7 for example, treats the two subjects in separate chapters with virtually no acknowledgement that they are related, let alone that they • Copyright 1981 by Boris I. Bittker. •• Sterling Professor of Law. Yale University. This article is the modified text of a speech delivered at the Fifth Annual William O. Douglas Lecture Series. October 30. 1980. I. Pub. L. No. 93-579, § 3, 88 Stat. 1897 (amended 1975 & 1977) codified at 5 U.S.C § 552a (1976». 2. Pub. L. No. 89-554, 80 Stat. 383 (1966) (amended 1967, 1974, 1976 & 1978) (codified at 5 U.S.C § 552 (1976».
    [Show full text]
  • Mayo Clinic, a Minnesota Corporation
    United States Court of Appeals For the Eighth Circuit ___________________________ No. 19-3189 ___________________________ Mayo Clinic, a Minnesota Corporation lllllllllllllllllllllPlaintiff - Appellee v. United States of America lllllllllllllllllllllDefendant - Appellant ____________ Appeal from United States District Court for the District of Minnesota ____________ Submitted: October 20, 2020 Filed: May 13, 2021 ____________ Before SMITH, Chief Judge, LOKEN and GRUENDER, Circuit Judges. ____________ LOKEN, Circuit Judge. Mayo Clinic (“Mayo”), a Minnesota nonprofit corporation, oversees healthcare system subsidiaries and operates the Mayo Clinic College of Medicine and Science (“Mayo College”). Mayo is a tax-exempt organization under Section 501(c)(3) of the Internal Revenue Code (IRC), 26 U.S.C. § 501(c)(3).1 After an audit in 2009, the Internal Revenue Service concluded that Mayo owed unrelated business income tax (“UBIT”) on certain investment income it received from the investment pool it manages for its subsidiaries. The IRS issued a Notice of Proposed Adjustment and reaffirmed its position in a 2013 Technical Advice Memorandum. At issue is $11,501,621 in UBIT for tax years 2003, 2005-2007, and 2010-2012. Mayo2 paid the tax and brought this refund action. The issue, briefly stated, is whether Mayo is a “qualified organization” exempted from paying UBIT on “unrelated debt-financed income” under IRC § 514(c)(9)(C)(i). Qualified organizations include “an organization described in section 170(b)(1)(A)(ii) . .” Section 170(b)(1)(A)(ii) describes “an educational organization which normally maintains a regular faculty and curriculum and normally has a regularly enrolled body of pupils or students in attendance at the place where its educational activities are regularly carried on.” The IRS denied Mayo the exemption because it is not an “educational organization” as defined in 26 C.F.R.
    [Show full text]
  • RESTORING the LOST ANTI-INJUNCTION ACT Kristin E
    COPYRIGHT © 2017 VIRGINIA LAW REVIEW ASSOCIATION RESTORING THE LOST ANTI-INJUNCTION ACT Kristin E. Hickman* & Gerald Kerska† Should Treasury regulations and IRS guidance documents be eligible for pre-enforcement judicial review? The D.C. Circuit’s 2015 decision in Florida Bankers Ass’n v. U.S. Department of the Treasury puts its interpretation of the Anti-Injunction Act at odds with both general administrative law norms in favor of pre-enforcement review of final agency action and also the Supreme Court’s interpretation of the nearly identical Tax Injunction Act. A 2017 federal district court decision in Chamber of Commerce v. IRS, appealable to the Fifth Circuit, interprets the Anti-Injunction Act differently and could lead to a circuit split regarding pre-enforcement judicial review of Treasury regulations and IRS guidance documents. Other cases interpreting the Anti-Injunction Act more generally are fragmented and inconsistent. In an effort to gain greater understanding of the Anti-Injunction Act and its role in tax administration, this Article looks back to the Anti- Injunction Act’s origin in 1867 as part of Civil War–era revenue legislation and the evolution of both tax administrative practices and Anti-Injunction Act jurisprudence since that time. INTRODUCTION .................................................................................... 1684 I. A JURISPRUDENTIAL MESS, AND WHY IT MATTERS ...................... 1688 A. Exploring the Doctrinal Tensions.......................................... 1690 1. Confused Anti-Injunction Act Jurisprudence .................. 1691 2. The Administrative Procedure Act’s Presumption of Reviewability ................................................................... 1704 3. The Tax Injunction Act .................................................... 1707 B. Why the Conflict Matters ....................................................... 1712 * Distinguished McKnight University Professor and Harlan Albert Rogers Professor in Law, University of Minnesota Law School.
    [Show full text]
  • The Background of the Revenue Act of 1937
    THE BACKGROUND OF THE REVENUE ACT OF 1937 RANDOLPzH E. PAUL* O N AUGUST 28, 1894, Congress enacted what was then considered a drastic income tax statute.' It carried a rate of 2%. The stat- ute was regarded by many with horror. Mr. Joseph H. Choate, then a leader of the New York bar, called the act "communistic in its pur- poses and tendencies," and confiscatory. 3 Words momentarily failed even Mr. Choate before the Supreme *Court, but he managed to label the prin- ciples upon which the tax was defended in that court as "communistic, socialistic-what shall I call them-populistic4 as ever have been ad- dressed to any political assembly in the world." s No attempt was made to circumvent this outrageous "direct" tax upon property. None was ever necessary. A direct frontal attack was made in the famous Pollock case and was successful by the recently noteworthy margin of five to four. Th6 decision, dose as it was, "forcibly interred"6 the contested statute and the nineteenth century had a peaceful ending. Taxpayers were safe until orderly constitutional process made the six- teenth Amendment effective on February 25, I913 Jand "direct" income taxation was possible without the impossible8 apportionment requirement. On this day the peace won by Mr. Choate proved merely a truce, and war was declared. In the beginning it was a quiet, good-natured conflictY It * Member of the New York bar. '28 Stat. 553 (1894), 31 U.S.C.A., § 372 (1929). 2 Pollock v. Farmers' Loan & Trust Co., 157 U.S. 429, 532 (1895).
    [Show full text]
  • Federal Register
    > 11TTTO& ' FEDERAL REGISTER VOLUME 3 \ 1934 NUMBER 141 i/AHTED^ W a sh in gton , T h u rsd a y, J u ly 21, 1938 Rules, Regulations, Orders his hand and caused the seal of the De­ CONTENTS partment of Agriculture to be affixed in the city of Washington, District of Co­ RULES, REGULATIONS, ORDERS TITLE 7—AGRICULTURE lumbia, this 19th day of July, 1938. T itle 7—A griculture: [ seal! M. L. W ilson, Agricultural Adjustment Ad­ AGRICULTURAL ADJUSTMENT Acting Secretary of Agriculture. ADMINISTRATION ministration: Page [F. R. Doc. 38-2079; Filed, July 20,1938; Fresh prunes grown in Uma­ P roclamation W ith Respect to B ase 9:32 a. m.] tilla County, Oreg., Walla P eriod to be U sed for P urpose of Walla and Columbia M arketing A greement and O rder Counties, Wash.: R egulating H andling of F resh P runes Base period for marketing G rown in U matilla County in State Order R egulating the H andling in In ­ agreement and order__1779 of Oregon, and W alla W alla and terstate and Foreign Commerce, and Order regulating handling Columbia Counties in State of W ash­ Such H andling as D irectly Burdens, in interstate, etc., com­ ington Obstructs or Affects I nterstate or F oreign Commerce of Fresh P runes merce_________________ 1779 By virtue of the authority vested in G rown in U matilla County in State Mainland cane sugar area the Secretary of Agriculture by the terms of Oregon and W alla W alla and Co­ ferais, determination of and provisions of Public Act No.
    [Show full text]
  • Administration's Fiscal Year 2014 Revenue Proposals
    General Explanations of the Administration’s Fiscal Year 2014 Revenue Proposals Department of the Treasury April 2013 General Explanations of the Administration’s Fiscal Year 2014 Revenue Proposals Department of the Treasury April 2013 This document is available online at: http://www.treasury.gov/resource-center/tax-policy/Documents/General-Explanations-FY2014.pdf TABLE OF CONTENTS ADJUSTMENTS TO THE BALANCED BUDGET AND EMERGENCY DEFICIT CONTROL ACT (BBEDCA) BASELINE .......................................... 1 Permanently Extend Increased Refundability of the Child Tax Credit ............................... 2 Permanently Extend Earned Income Tax Credit (EITC) for Larger Families and Married Couples ................................................................................................................... 4 Permanently Extend the American Opportunity Tax Credit (AOTC) ................................. 6 RESERVE FOR REVENUE-NEUTRAL BUSINESS TAX REFORM ............. 9 INCENTIVES FOR MANUFACTURING, RESEARCH, CLEAN ENERGY, AND INSOURCING AND CREATING JOBS ............................................................................. 10 Provide Tax Incentives for Locating Jobs and Business Activity in the United States and Remove Tax Deductions for Shipping Jobs Overseas ........................................... 10 Provide New Manufacturing Communities Tax Credit .................................................... 12 Enhance and Make Permanent the Research and Experimentation (R&E) Tax Credit ... 13 Extend Certain Employment Tax
    [Show full text]
  • Report No. 82-156 Gov Major Acts of Congress And
    REPORT NO. 82-156 GOV MAJOR ACTS OF CONGRESS AND TREATIES APPROVED BY THE SENATE 1789-1980 Christopher Dell Stephen W. Stathis Analysts in American National Governent Government Division September 1982 CONmGHnItNA^l JK 1000 B RE filmH C SE HVICA^^ ABSTRACT During the nearly two centuries since the framing of the Constitution, more than 41,000 public bills have been approved by Congress, submitted to the President for his approval and become law. The seven hundred or so acts summarized in this compilation represent the major acts approved by Congress in its efforts to determine national policies to be carried out by the executive branch, to authorize appropriations to carry out these policies, and to fulfill its responsibility of assuring that such actions are being carried out in accordance with congressional intent. Also included are those treaties considered to be of similar importance. An extensive index allows each entry in this work to be located with relative ease. The authors wish to credit Daphine Lee, Larry Nunley, and Lenora Pruitt for the secretarial production of this report. CONTENTS ABSTRACT.................................................................. 111 CONGRESSES: 1st (March 4, 1789-March 3, 1791)..................................... 3 2nd (October 24, 1791-March 2, 1793)................................... 7 3rd (December 2, 1793-March 3, 1795).................................. 8 4th (December 7, 1795-March 3, 1797).................................. 9 5th (May 15, 1797-March 3, 1799)....................................... 11 6th (December 2, 1799-March 3, 1801)................................... 13 7th (December 7, 1801-Marh 3, 1803)................................... 14 8th (October 17, 1803-March 3, 1805)....... ........................... 15 9th (December 2, 1805-March 3, 1807)................................... 16 10th (October 26, 1807-March 3, 1809)..................................
    [Show full text]
  • Vol. 6, No. 2: Full Issue
    Denver Journal of International Law & Policy Volume 6 Number 2 Spring Article 11 May 2020 Vol. 6, no. 2: Full Issue Denver Journal International Law & Policy Follow this and additional works at: https://digitalcommons.du.edu/djilp Recommended Citation 6 Denv. J. Int'l L. & Pol'y This Full Issue is brought to you for free and open access by the University of Denver Sturm College of Law at Digital Commons @ DU. It has been accepted for inclusion in Denver Journal of International Law & Policy by an authorized editor of Digital Commons @ DU. For more information, please contact [email protected],dig- [email protected]. DENVER JOURNAL OF INTERNATIONAL LAW AND POLICY VOLUME 6 1976-1977 Denver Journal OF INTERNATIONAL LAW AND POLICY VOLUME 6 NUMBER 2 SPRING 1977 INTERNATIONAL ASPECTS OF THE TAX REFORM ACT OF 1976 TAXING BoYcorrs AND BRIBES ........................................... G. C . Hufbauer J. G. Taylor 589 The authors examine the tax penalty provisions of the Tax Reform Act of 1976 and the Export Administration Act Amendments of 1977 in relation to U.S. persons who "participate in or cooperate with" international boycotts or bribery. The article discusses the various types of international boycotts and the penalty, computational, and reporting requirements imposed on participants as clarified by the Treasury Guidelines and Revenue Proce- dures. The authors conclude with a discussion of the novelty, complexity, and potential impact of the legislation. TAKING SIDES: AN OVERVIEW OF THE U.S. LEGISLATIVE RESPONSE TO THE ARAB BOYCOTT ............................................ John M . Tate Ralph B. Lake 613 The current legislative scheme in opposition to the Arab boycott is generally directed against the Arab League countries' secondary and tertiary, indirect forms of boycott.
    [Show full text]
  • America's Economic Way Of
    |America’s Economic Way of War How did economic and financial factors determine how America waged war in the twentieth century? This important new book exposes the influence of economics and finance on the questions of whether the nation should go to war, how wars would be fought, how resources would be mobilized, and the long-term consequences for the American economy. Ranging from the Spanish–American War to the Gulf War, Hugh Rockoff explores the ways in which war can provide unique opportunities for understanding the basic principles of economics as wars produce immense changes in monetary and fiscal policy and so provide a wealth of infor- mation about how these policies actually work. He shows that wars have been more costly to the United States than most Americans realize as a substantial reliance on borrowing from the public, money creation, and other strategies to finance America’s war efforts have hidden the true cost of war. hugh rockoff is a professor of Economics at Rutgers, the State University of New Jersey, and a research associate of the National Bureau of Economic Research. His publications include numerous papers in professional journals, The Free Banking Era: A Re-examination (1975), Drastic Measures: A History of Wage and Price Controls in the United States (1984), and a textbook, History of the American Economy (2010, with Gary Walton). NEW APPROACHES TO ECONOMIC AND SOCIAL HISTORY series editors Nigel Goose, University of Hertfordshire Larry Neal, University of Illinois, Urbana-Champaign New Approaches to Economic and Social History is an important new textbook series published in association with the Economic History Society.
    [Show full text]