DynCorp International, LLC, a U.S. company, and Aramco, a Saudi-owned corporation, entered into a contract for a computer system which was to be manufactured in the U.S. and installed at Aramco’s facilities in Saudi Arabia. The contract contained a choice of law provision requiring the...

Financial accounting is an information conveyance process. When financial auditors issue an opinion in regard to financial statements, the auditors are providing assurance that those financial statements fairly represent the entity, and are prepared in accordance with the relevant standards. If...

Internal Revenue Code (IRC) §§ 6662(b) authorizes the Internal Revenue Service (IRS) to impose a penalty if an underpayment of income tax by a taxpayer exceeds a computational threshold called a substantial understatement. An understatement is reduced, however, by the portion attributable to...

The statutory language of the Internal Revenue Code gives cognizance to the methods of accounting used by taxpayers for their financial reporting. The 1979 U.S. Supreme Court opinion of Thor Power acceded to the Internal Revenue Service a significant amount of discretion in its attempt to...

In the wake of the recent financial meltdown, financial reporting under both North American generally accepted accounting principles (GAAP) and international financial reporting standards (IFRS) has involved renewed attention to the structures and constraints of “mark-to-market” and similar...