9th Circuit Deals Blow To U.S. Government on Canada Tax Treaty Summons

IMPORTANT: The full content of this page is available to premium users only.

Wednesday, April 1, 1987
Author: 
Bruce Zagaris
Volume: 
3
Issue: 
4
Abstract: 
In a decision of March 24, 1987, the Ninth Circuit Court of appeals in a 2 to 1 decision held that, rather than meeting the liberal standard showing only "institutional good faith", the U.S. Government must show whether there has been a referral of the case to the Justice Department for criminal prosecution.