"Microsoft's Bermuda Subsidiaries Subject To Tax Inquiry, Documents Show"The Huffington Post
Linda Carlisle was quoted regarding a recent order under the Tax Information Exchange Agreement (TIEA) in Bermuda. Carlisle said when clients are on the business end of these information requests, they take the matter very seriously. "The TIEA is where the Internal Revenue Service or the Treasury Department comes in and says, 'It's necessary for me, in the enforcement of my domestic laws, to get information that you may have in your possession or can get, foreign government, and you agree to give that to me,' Carlisle said. "The information has to be specifically requested, so if I'm the United States getting information under a TIEA, I'm looking at a specific taxpayer and I have some reason to assume there's a question under my laws. It's more than just, 'Oh, we always ask for this all the time.'"
For the TIEA order to make it to the Bermuda court, it was first vetted by the Bermuda government, Carlisle said. "The government first determines if the request has been made sufficiently for it to go out to its taxpayers," she said. "Because, remember, this is a government-to-government agreement. The government first determines, 'Has the United States been specific enough in their request for me to act?' Assuming they have, then the foreign government goes out to one of its taxpayers and says, 'Oh, by the way, I love you dearly. I'm collecting information on behalf of the Internal Revenue Service of the United States.'"