U.S. President Barack Obama is set to meet Friday and
Saturday with Chinese President Xi Jinping. Their discussions
were likely to focus on other topics, but New York Senator
Charles Schumer has urged the two leaders to take up the
auditing issue.

“It is in the interests of both U.S. financial markets and
Chinese companies seeking to raise money here that investors
know they can trust the financial statements of those
companies,” Schumer said in June 6 letter to U.S. Treasury
Secretary Jack Lew ahead of the Obama-Xi summit.

A likelier forum for the issue will come on July 8 at a
meeting of senior economic officials, including Lew. The final
agenda for these sessions was still being shaped. Business
groups want it to include the Chinese auditing issue.

The U.S.-China relationship is vital to both countries, but
fraught with tensions, not the least of which involve China’s
willingness and ability to comply with accounting and financial
standards widely accepted across the developed world.

Looming in the background of this weekend’s and next month’s
talks will be a handful of Chinese initial public offerings
aiming to hit U.S. stock markets soon.

“At a time when China-based companies are once again seeking
to issue securities on U.S. stock exchanges, I urge you and the
president to ensure this issue receives serious consideration,”
Schumer wrote to Lew.

LONG-FESTERING DISPUTE

U.S. and Chinese audit regulators have been at an impasse
for more than two years over how to oversee auditing of
China-based companies that list and trade on U.S. stock
exchanges.

Accounting scandals have erupted among many of these
businesses and U.S. investors have been burned. The Public
Company Accounting Oversight Board (PCAOB), which polices
auditors of U.S.-listed corporations, wants to have a closer
look at how audit firms review the books of Chinese companies.

But the Chinese government has barred the PCAOB from doing
routine inspections in China, citing national sovereignty.

The PCAOB and China on May 24 announced an agreement that
will allow U.S. regulators to obtain audit documents for
enforcement cases, but will not allow inspections in China.

The PCAOB “has had a half bite of the apple,” said U.S.
Chamber of Commerce Vice President Tom Quaadman.

Treasury needs to take the next bite by pressing China for
an expansion of the PCAOB pact, said Quaadman, on behalf of the
chamber, the largest U.S. lobbying group for businesses.

Also pushing for a broader deal are the Big Four global
accounting firms and their clients, U.S. multinationals that do
business in China. They worry a lack of transparency and a
history of accounting problems at Chinese firms could lead to
harsher scrutiny of their own Chinese financial statements by
the U.S. Securities and Exchange Commission.

PCAOB Chairman Jim Doty described the May 24 deal as a step
toward more cooperation with Chinese regulators. Negotiations
continue and the next step will be getting access to documents
for inspections, he said.

FIRST IPO SINCE NOVEMBER

An IPO on Thursday of LightInTheBox Holding Co Ltd
- the first U.S.-listed IPO of a Chinese company since November
- may have signaled some market confidence in the partial May 24
deal. Shares of online merchant LightInTheBox rose 32 percent in
their first two days of trading.

At least five other small Chinese technology companies are
considering U.S. IPOs and their outlook may hinge on the ability
of the PCAOB and China to seal a broader deal, analysts said.

Formed a decade ago as part of the post-Enron Sarbanes-Oxley
corporate auditing reform laws, the PCAOB has a powerful weapon.
It can deregister audit firms that fail to comply with its
rules. Firms which are not registered with the PCAOB cannot
audit U.S. public companies.

Sixteen countries have agreed to allow the PCAOB to review
audits done within their borders for U.S.-traded companies,
including Germany, Japan, Canada, South Korea and Britain.

Monday, June 10 – Wednesday, June 12

Federation of Tax Administrators annual meeting. Hyatt Regency. Albuquerque, New Mexico.

 Tuesday, June 11

U.S. Internal Revenue Service and Treasury Department officials join panel on recent changes to corporate taxation regulations covering corporate sales or distribution of stock in another corporation. Noon – 1:45 p.m. ET, D.C. Bar Conference Center. Washington

 Tuesday, June 11 – Thursday, June 13

IRS and Treasury Department officials, among others, speak to the Practising Law Institute’s seminar on tax planning for domestic and foreign partnerships and other alliances. San Francisco.

 Wednesday, June 12

Speaker of the U.S. House of Representatives John Boehner, Congressman Bob Goodlatte, chairman of the House Judiciary Committee, and Congressman Dave Camp, chairman of the House Ways and Means Committee, among other members of Congress, address BakerHostetler’s Tax, Budget & Health Care Policy Seminar. 7:30 a.m. – 1:30 p.m. ET, Hyatt Regency Capitol Hill. Washington.

Wednesday, June 12 – Friday, June 14

American Bar Association meeting on wealth and asset planning, and U.S.-Latin America tax planning strategies. Mandarin Oriental Hotel. Miami.

(Reuters) – The regulator of corporate auditors said on Thursday that the U.S. arm of global accounting firm Ernst & Young failed to fix quality control problems found in earlier reviews.

The report from the Public Company Accounting Oversight Board (PCAOB) is a blow for the firm, which markets itself as a global leader in audit quality.

It followed the PCAOB’s 2009 inspection of 58 Ernst & Young audits. The inspection led the watchdog to criticize how the firm audited clients’ estimates of numbers key to the accuracy of their clients’ financial statements.

Problems were found with Ernst & Young’s evaluation of the accuracy of clients’ estimates of asset impairment and the size of reserves companies took against issues such as environmental problems and expired inventory, among other things.

The PCAOB also raised concerns about the supervision of auditors, their professional skepticism, and Ernst & Young’s evaluation of areas posing fraud risk.

An Ernst & Young spokeswoman did not take issue with the PCAOB’s findings and praised the inspection process as useful. The firm pledged to continue to work cooperatively with the board to improve the quality of its audits.

Ernst & Young has decided not to appeal the decision to the U.S. Securities and Exchange Commission, as is its right, according to the PCAOB report.

Two other Big Four audit and accounting firms — PricewaterhouseCoopers and Deloitte & Touche — have received similar criticism in earlier PCAOB reports.

(Reporting by Nanette Byrnes; Editing by Kevin Drawbaugh and Sofina Mirza-Reid)

Some important dates in the week ahead:

 Monday, May 20

Securities and Exchange Commission accountants address SEC financial reporting at the Compliance Week annual conference. Washington.

 Monday, May 20 – Tuesday, May 21

The American Institute of Certified Public Accountants conference on income and estate taxes and high-income taxpayers, and other topics. Las Vegas.

 Monday, May 20 – Wednesday, May 22

The Council on State Taxation program on state income and franchise taxes. New Orleans.

Tuesday, May 21

* Apple’s chief executive officer and chief financial officer testify at Senate Homeland Security and Governmental Affairs Permanent Subcommittee on Investigations hearing on multinational corporations shifting profits offshore. 9:30 a.m. ET, Dirksen Senate Office Building. Washington.

* Former IRS acting director Steven Miller, former IRS director Doug Shulman, and Treasury Inspector General for Tax Administration Russell George appear at Senate Finance Committee hearing on the Internal Revenue Service’s 501(c)4 reviews. 10 a.m. ET, Dirksen Senate Office Building. Washington.

* Martin Baumann, chief auditor of the Public Company Accounting Oversight Board, Jeanette Franzel, board member, and Deloitte & Touche CEO Gregory Weaver speak on the state of the audit industry and auditor regulation at the Compliance Week conference. Washington.

 Tuesday, May 21 – Thursday, May 23

Practicing Law Institute program on tax planning for domestic and foreign partnerships and other structures. New York and San Francisco.

Wednesday, May 22

Treasury Secretary Neal Wolin and IRS exempt organizations chief Lois Lerner are among those speaking at the House of Representatives Oversight and Government Reform Committee hearing on the IRS’s treatment of political groups. 9:30 a.m. ET, Rayburn House Office Building. Washington.

 Thursday, May 23

Financial Accounting Standards Board meeting on revenue recognition, insurance contracts and other topics. 8 a.m. ET, FASB offices. Norwalk, Connecticut.

 Friday, May 24

Video webcast of the joint video conference of FASB and the International Accounting Standards Board. 7:30 a.m. ET.

(Reuters) – The House of Representatives Ways and Means Committee on Friday will hold the first of three hearings on the Internal Revenue Service “Tea Party” targeting scandal.

Tax experts hope the hearings go beyond finger-pointing and get to the heart of the IRS’s long-standing problems. If they can get past the fist-pounding stage, here are some questions lawmakers should ask:

* Why do IRS reviews take so long?

According to the IRS website, the tax exempt organizations sections is assigning agents to review applications filed more than a year ago. Long delays for 501(c)4 applicants were highlighted in a Treasury Inspector General for Tax Administration (TIGTA) report that detailed the scandal.

Such delays are relatively new, said a former IRS exempt organizations executive. Reducing delays is crucial, he said.

* How can oversight from Washington be improved?

Poor leadership was a big factor in the scandal, TIGTA said. In the IRS’ tax exempt section, leadership and legal counsel are located in Washington, while the Cincinnati office reviews applications. Some decisions made in Cincinnati would have been better made in Washington, former IRS staff said.

* Why is the IRS not complying with all of the Inspector General’s recommendations?

The TIGTA report published Tuesday said the IRS is taking the unusual step of not complying with two TIGTA recommendations. Tax experts said that raises red flags.

* What expertise does the IRS have in sorting data?

With 70,000 annual filings to review and a staff of just 200, the IRS non-profit arm has to find a way to sort through applications that is fair and non-partisan. One former IRS executive said working with experts in constructing random samples of large data sets would help.

* Should the IRS be doing this at all?

The duties of the IRS have expanded over time. The number of organizations applying for 501(c)(4) status has doubled since 2010, while the IRS’ budget has shrunk. The IRS may need to shed its non-profit duties, one lawyer proposed.

* How can it be ensured that the IRS doesn’t just give up on monitoring these entities, post-scandal?

If Congress does not want to end up subsidizing political action with tax breaks, it will have to make sure a chill does not descend on the IRS. Past initiatives to examine politicking by traditional charities found evidence of a growing problem, but were politically touchy, and faded eventually.

(Reporting by Nanette Byrnes; Editing by Kevin Drawbaugh and Cynthia Osterman)

After declining for two years, the number of companies that
hired a tax lobbyist, or lobbied on tax issues using in-house
staff, rose modestly to 1,509 in the first three months of 2013,
up from 1,487 during the same quarter a year ago, according to
government filings analyzed by the nonpartisan watchdog group
the Center for Responsive Politics.

Coinciding with the start of a new session of Congress, the
analysis shows it is the busiest first quarter for tax lobbying
since 2010, when President Barack Obama set up the bipartisan
Simpson-Bowles commission to find a solution to the country’s
growing deficit, including changes to the tax code.

This year’s climb in the tax lobbyist population comes at a
time when revamping the tax code is on the minds of some
decision-makers, though comprehensive legislation has yet to
emerge.

Obama says he wants a tax code overhaul. So do the chairmen
of Congress’s two tax-writing committees – Democratic Senator
Max Baucus of Montana and Republican Representative Dave Camp of
Michigan who together created TaxReform.gov, a website that asks
Americans to share their stories and ideas about tax reform.

Opinion polls show the public wants a simpler tax code, but
political obstacles stand in the way. The last overhaul was in
1986. A lack of political consensus in Congress on whether tax
reform should raise new federal revenues is a problem. So is
division within the business community about changing the code.

The expanding ranks of tax lobbyists are both a result of
the push for change and likely to prove one of its greatest
impediments, with each lobbyist paid substantial sums of money
to defend and, if possible, expand the narrow interests of their
clients.

More than 2,220 organizations spent an estimated $773
million hiring 6,503 lobbyists to advocate on 1,454 tax-related
bills in the 2011-2012 Congress, said the non-profit Sunlight
Foundation, another government influence watchdog group.

That represented roughly 12 lobbyists for each of the 535
members of the U.S. Senate and U.S. House of Representatives.

Peter Metzger, Washington-based vice chairman of executive
head-hunting firm CTPartners, estimates based on what his firm
is seeing in the marketplace that demand for tax lobbyists and
tax lawyers in Washington is up 25 to 30 percent this year.
Metzger’s office specializes in recruiting government relations
staff and lobbyists, among other fields.

The title of a recent client advisory from lobbying law firm
K&L Gates was: “If you are not at the table, you’re on the
menu.”

TECH GIANTS EXPAND IN D.C.

In the first three months of 2013, online retail giant
Amazon.com Inc spent $1.2 million on in-house and
external lobbyists who lobbied on tax, and usually other topics
too, according to federal filings. That is up from $870,000 in
the prior year’s first quarter.

Lobbying firms generally represent their clients on multiple
issues, and exactly how much of their fees relate to lobbying on
taxes is not disclosed.

Amazon backed a measure that passed the U.S. Senate this
month to give states the power to enforce their sales tax laws
on online purchases.

Amazon employs a couple of firms which lobbied exclusively
on Internet sales tax legislation, in the first quarter of this
year.

Amazon paid such firms $250,000, according to lobbying
reports filed in April by two firms, Patton Boggs and
Forbes-Tate, with the House of Representatives and Senate. Of
that, $220,000 went to lobbyists from Patton Boggs, including
former senators John Breaux and Trent Lott, according to their
April 20 lobbying report.

In addition, lobbying firm TwinLogic Strategies disclosed in
its April 21 Amazon lobbying report that Elizabeth Frazee, a
former top aide to House Judiciary Committee Chairman Bob
Goodlatte, was also lobbying on the Internet sales tax
legislation. The Virginia Republican’s committee will be the
first to consider online legislation in the House, where the
legislation faces a tougher fight.

Amazon declined comment on its lobbying efforts.

Software maker Microsoft Corp has more lobbyists
working on tax issues so far this year than any other company,
according to an analysis of filings done by the Center for
Responsive Politics.

All together, in the first quarter of 2013, Microsoft spent
over $3 million on lobbyists who reported spending at least some
of their time working on taxes, up from $2.2 million in the
comparable period of 2012.

Microsoft, which now has $66 billion in cash sitting
overseas according to its most recent quarterly filing with the
Securities and Exchange Commission, was part of a coalition of
companies pushing for legislation that would enable them to
bring earnings home to the United States without paying the full
tax on them.

It is a controversial proposal because the last such tax
break, in 2004, failed to produce the domestic jobs and
investment Congress had hoped for.

The company’s in-house lobbying staff and eight of its
outside lobbying firms list international tax reform proposals
as a topic they have contacted lawmakers about in lobbying
reports filed with Congress.

One of those outside firms, Ernst & Young, listed a bill by
Senator Bernie Sanders, a Vermont Independent, that seeks to end
the company’s current ability to defer taxes on income earned
abroad, as one of the bills it has been discussing on Capitol
Hill.

Microsoft has reported that it would owe $19.4 billion in
federal income tax if it were to bring its overseas cash to the
United States at current tax rates.

The company did not respond to a request for comment on its
lobbying efforts.

(Reuters) – The Justice Department said on Tuesday that a federal court had authorized the Internal Revenue Service to seek information on U.S. taxpayers who may have accounts at Canadian Imperial Bank of Commerce FirstCaribbean International Bank (FCIB).

In a move resembling a recent IRS inquiry into Americans with Swiss bank accounts, the Justice Department said a court order would let the IRS serve a ‘John Doe’ summons seeking records of FCIB’s U.S. correspondent account at Wells Fargo & Co. A correspondent account is a bank deposit account maintained by one bank for another bank.

The order would allow the IRS to identify U.S. taxpayers with “interests in financial accounts at FCIB and other financial institutions that used FCIB’s Wells Fargo correspondent account,” the Justice Department said in a statement.

“Our work here shows our resolve to pursue these cases in all parts of the world, regardless of whether the person hiding money overseas chooses a bank with no offices on U.S. soil,” IRS Acting Commissioner Steven Miller said in a statement.

A spokesman for Wells Fargo said the bank would “review the summons and respond as legally required.”

An FCIB spokeswoman said the bank intended to “cooperate with authorities in accordance with the respective laws of all jurisdictions involved” and to comply with legal and regulatory requirements. The bank was working with Wells Fargo to understand the court order, she said in a prepared statement.

FCIB, based in Barbados, has branches in 18 Caribbean countries. According to its website, the bank was formed in 2002 by Britain’s Barclays Bank and Canadian Imperial Bank of Commerce (CIBC). In 2006, CIBC became the bank’s majority shareholder, according to the website.

CIBC did not immediately reply to requests for comment.

FCIB does not have U.S. branches but it has a correspondent account in the United States at Wells Fargo, Justice said.

The IRS uses ‘John Doe’ summonses to get information on possible tax law breakers whose identities are unknown. “This John Doe summons directs Wells Fargo to produce records identifying U.S. taxpayers with accounts at FCIB and other banks that used FCIB’s correspondent account,” the statement said.

In a declaration filed to the court, a senior IRS revenue agent said many FCIB customers in the John Doe class may have been under-reporting income, evading income taxes, or otherwise violating the internal revenue laws of the United States.

The FCIB case stemmed from information from 129 customers of the Barbados bank and its predecessor banks who took part in an IRS voluntary disclosure program, the Justice Department said.

In a similar case in January 2013, a federal court allowed the IRS to serve a ‘John Doe’ summons on Switzerland’s UBS AG, seeking records of Swiss bank Wegelin & Co.’s U.S. correspondent account at UBS.

That action was part of a wide-ranging U.S. government effort to crack down on tax avoidance by Americans.

Wegelin, Switzerland’s oldest bank, in March agreed to pay nearly $58 million in penalties and said it would shut its doors after admitting to helping wealthy Americans evade taxes.

The serving of ‘John Doe’ summons on correspondent accounts is likely to become more common as the government widens its tax inquiries beyond Switzerland, Luxembourg and Liechtenstein, said William Sharp, a lawyer who represents taxpayers.

(Editing by Kevin Drawbaugh, Chris Reese and Andrew Hay)

(Reuters) – The Justice Department said on Tuesday that a federal court had authorized the Internal Revenue Service to seek information on U.S. taxpayers who may have accounts at Canadian Imperial Bank of Commerce FirstCaribbean International Bank (FCIB).

In a move resembling a recent IRS inquiry into Americans with Swiss bank accounts, the Justice Department said a court order would let the IRS serve a ‘John Doe’ summons seeking records of FCIB’s U.S. correspondent account at Wells Fargo & Co. A correspondent account is a bank deposit account maintained by one bank for another bank.

The order would allow the IRS to identify U.S. taxpayers with “interests in financial accounts at FCIB and other financial institutions that used FCIB’s Wells Fargo correspondent account,” the Justice Department said in a statement.

“Our work here shows our resolve to pursue these cases in all parts of the world, regardless of whether the person hiding money overseas chooses a bank with no offices on U.S. soil,” IRS Acting Commissioner Steven Miller said in a statement.

FCIB and CIBC did not immediately reply to requests for comment.

A spokesman for Wells Fargo said the bank would “review the summons and respond as legally required.”

FCIB, based in Barbados, has branches in 18 Caribbean countries. According to its website, the bank was formed in 2002 by Britain’s Barclays Bank and CIBC. In 2006, CIBC became the bank’s majority shareholder, according to the website.

FCIB does not have U.S. branches but it has a correspondent account in the United States at Wells Fargo, Justice said.

The IRS uses ‘John Doe’ summonses to get information on possible tax law breakers whose identities are unknown. “This John Doe summons directs Wells Fargo to produce records identifying U.S. taxpayers with accounts at FCIB and other banks that used FCIB’s correspondent account,” the statement said.

In a declaration filed to the court, a senior IRS revenue agent said many FCIB customers in the John Doe class may have been under-reporting income, evading income taxes, or otherwise violating the internal revenue laws of the United States.

The FCIB case stemmed from information from 129 customers of the Barbados bank and its predecessor banks who took part in an IRS voluntary disclosure program, the Justice Department said.

In a similar case in January 2013, a federal court allowed the IRS to serve a ‘John Doe’ summons on Switzerland’s UBS AG, seeking records of Swiss bank Wegelin & Co.’s U.S. correspondent account at UBS.

That action was part of a wide-ranging U.S. government effort to crack down on tax avoidance by Americans.

Wegelin, Switzerland’s oldest bank, in March agreed to pay nearly $58 million in penalties and said it would shut its doors after admitting to helping wealthy Americans evade taxes.

The serving of ‘John Doe’ summons on correspondent accounts is likely to become more common as the government widens its tax inquiries beyond Switzerland, Luxembourg and Liechtenstein, said William Sharp, a lawyer who represents taxpayers.

(Reporting by Nanette Byrnes; Editing by Kevin Drawbaugh and Chris Reese)

In a move resembling a recent IRS inquiry into Americans
with Swiss bank accounts, the Justice Department said a court
order would let the IRS serve a ‘John Doe’ summons seeking
records of FCIB’s U.S. correspondent account at Wells Fargo & Co
. A correspondent account is a bank deposit account
maintained by one bank for another bank.

The order would allow the IRS to identify U.S. taxpayers
with “interests in financial accounts at FCIB and other
financial institutions that used FCIB’s Wells Fargo
correspondent account,” the Justice Department said in a
statement.

“Our work here shows our resolve to pursue these cases in
all parts of the world, regardless of whether the person hiding
money overseas chooses a bank with no offices on U.S. soil,” IRS
Acting Commissioner Steven Miller said in a statement.

FCIB and CIBC did not immediately reply to requests
for comment.

A spokesman for Wells Fargo said the bank would “review the
summons and respond as legally required.”

FCIB, based in Barbados, has branches in 18 Caribbean
countries. According to its website, the bank was formed in 2002
by Britain’s Barclays Bank and CIBC. In 2006, CIBC
became the bank’s majority shareholder, according to the
website.

FCIB does not have U.S. branches but it has a correspondent
account in the United States at Wells Fargo, Justice said.

The IRS uses ‘John Doe’ summonses to get information on
possible tax law breakers whose identities are unknown. “This
John Doe summons directs Wells Fargo to produce records
identifying U.S. taxpayers with accounts at FCIB and other banks
that used FCIB’s correspondent account,” the statement said.

In a declaration filed to the court, a senior IRS revenue
agent said many FCIB customers in the John Doe class may have
been under-reporting income, evading income taxes, or otherwise
violating the internal revenue laws of the United States.

The FCIB case stemmed from information from 129 customers of
the Barbados bank and its predecessor banks who took part in an
IRS voluntary disclosure program, the Justice Department said.

In a similar case in January 2013, a federal court allowed
the IRS to serve a ‘John Doe’ summons on Switzerland’s UBS AG
, seeking records of Swiss bank Wegelin & Co.’s U.S.
correspondent account at UBS.

That action was part of a wide-ranging U.S. government
effort to crack down on tax avoidance by Americans.

Wegelin, Switzerland’s oldest bank, in March agreed to pay
nearly $58 million in penalties and said it would shut its doors
after admitting to helping wealthy Americans evade taxes.

The serving of ‘John Doe’ summons on correspondent accounts
is likely to become more common as the government widens its tax
inquiries beyond Switzerland, Luxembourg and Liechtenstein, said
William Sharp, a lawyer who represents taxpayers.

In a move resembling a recent IRS inquiry into Americans
with Swiss bank accounts, the department said a court order will
let the IRS serve a ‘John Doe’ summons seeking records of FCIB’s
U.S. correspondent account at Wells Fargo & Co.

A correspondent account is a bank deposit account maintained
by one bank for another bank.

The order will allow the IRS to identify U.S. taxpayers with
“interests in financial accounts at FCIB and other financial
institutions that used FCIB’s Wells Fargo correspondent
account,” the Justice Department said in a statement.

Requests for comment to FCIB, CIBC and Wells Fargo
were not immediately returned.

FCIB, based in Barbados, has branches in 18 Caribbean
countries. According to its web site, the bank was formed in
2002 by Britain’s Barclays Bank and CIBC. In 2006,
CIBC became the bank’s majority shareholder, the site said.

FCIB does not have U.S. branches, but has a correspondent
account in the United States at Wells Fargo, Justice said.

The IRS uses ‘John Doe’ summonses to get information on
possible tax law breakers whose identities are unknown. “This
John Doe summons directs Wells Fargo to produce records
identifying U.S. taxpayers with accounts at FCIB and other banks
that used FCIB’s correspondent account,” the statement said.

In a declaration filed to the court, a senior IRS revenue
agent said many FCIB customers in the John Doe class may have
been under-reporting income, evading income taxes, or otherwise
violating the internal revenue laws of the United States.

In a similar case in January 2013, a federal court allowed
the IRS to serve a ‘John Doe’ summons on Switzerland’s UBS AG
, seeking records of Swiss bank Wegelin & Co.’s U.S.
correspondent account at UBS.

That action was part of a wide-ranging U.S. government
effort to crack down on tax avoidance by Americans.

Wegelin, Switzerland’s oldest bank, in March agreed to pay
nearly $58 million in penalties and said it would shut its doors
after admitting to helping wealthy Americans evade taxes.

The serving of ‘John Doe’ summons on correspondent accounts
is likely to become more common as the government widens its tax
inquiries beyond Switzerland, Luxembourg and Liechtenstein, said
William Sharp, a lawyer who represents taxpayers.