Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter.
Exchange of information on request mandates cross-border sharing of tax-relevant financial and ownership records for investigations. Exchange of information on request requires the requested Party's competent authority to provide tax-relevant information and to use all available information-gathering measures, including obtaining records and witness depositions where allowed. Authorities must be able to access records from banks, financial institutions, agents, nominees and trustees and to secure legal and beneficial ownership information for entities and ownership chains, subject to a limitation for publicly traded companies and public funds. Requests must establish foreseeable relevance by identifying the person, period, nature and tax purpose of the request, grounds for the information's location, and confirmation that domestic means were pursued; the requested authority must acknowledge requests, notify deficiencies and either supply information or explain any inability promptly.
Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
Provisions expressly mentioned in the judgment/order text.
Exchange of information on request mandates cross-border sharing of tax-relevant financial and ownership records for investigations.
Exchange of information on request requires the requested Party's competent authority to provide tax-relevant information and to use all available information-gathering measures, including obtaining records and witness depositions where allowed. Authorities must be able to access records from banks, financial institutions, agents, nominees and trustees and to secure legal and beneficial ownership information for entities and ownership chains, subject to a limitation for publicly traded companies and public funds. Requests must establish foreseeable relevance by identifying the person, period, nature and tax purpose of the request, grounds for the information's location, and confirmation that domestic means were pursued; the requested authority must acknowledge requests, notify deficiencies and either supply information or explain any inability promptly.
Full Summary is available for active users!
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
AI Drafter - (New and Powerful) ✕
Generate professional replies, appeals, opinions to Show Cause Notices, assessment orders, audit objections, and other legal communications using TaxTMI's AI Drafter. 
of 
TaxTMI 
