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The Branch Profits Tax (BPT) under I.R.C. Section 884, is a U.S. federal income tax levied on foreign corporations that conduct business through branches located within the United States. Its purpose is...
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The Internal Revenue Code (IRC) provides for the confidentiality of taxpayer tax returns and return information. In general, employees and officers of the federal government, certain employees and officers of states or state and local agencies, and other persons with access to such returns or return information are required to keep tax return and return information confidential unless authorized by the IRC. This practice note contains a diagram breaking down the factors to consider and the questions to ask in determining whether there is an I.R.C. § 6103 violation and, if so, whether a taxpayer may have a civil action against the United States under I.R.C. § 7431 for damages.
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