Review article: Zambia's foreign policy: themes and approaches
Marcia Burdette Zambia: Between Two Worlds Boulder: Westview Press, 1988. Stephen Chan Kaunda and Southern Africa: Image and Reality in Foreign Policy London: British Academic Press, 1992. Timothy Shaw and Douglas Anglin Zambia's Foreign Policy; Studies in Diplomacy and Dependency Boulder: Westview Press, 1979.
Zambia and the Liberation of South Africa
The nine member-states of the Southern African Development Coordination Conference (S.A.D.C.C.) – Zimbabwe, Zambia, Angola, Mozambique, Botswana, Tanzania, Malawi, Lesotho, Swaziland – are notable for their collective weakness relative to South Africa, and their very wide economic and political heterogeneity.1 Only four, or at most five, have economies whose annual G.D.P. exceeds $2,000 million: two of these, Angola and Mozambique, are under more or less constant attack from South Africa or its surrogate forces, while Tanzania is actually the most remote, physically and economically. At the same time, Malawi, Swaziland, and Lesotho – who are not in the so-called ‘Frontline’, unlike the other six – have rather close political relations with Pretoria, Malawi most substantively since as early as 1966 and Swaziland since 1982.2 Botswana is more independent politically, with a modest G.D.P. and very small population.
The Timing of Tax Transparency
Fairness in the administration of the tax law is the subject of intense debate in the United States. As recent headlines reveal, the Internal Revenue Service has been accused of failing to enforce the tax law equitably in its review of tax-exempt status applications by political organizations, the international tax structures of multinational corporations, and the estate tax returns of millionaires, among other areas. Many have argued that greater “tax transparency” would better empower the public to hold the IRS accountable and the IRS to defend itself against accusations of malfeasance. Mandatory public disclosure of taxpayers’ tax return information is often proposed as a way to achieve greater tax transparency. Yet, in addition to concerns regarding exposure of personal and proprietary information, broad public disclosure measures pose potential threats to the taxing authority’s ability to enforce the tax law.Given the competing values of accountability and enforcement, what tax return information should be observable by the public? This Article argues that timing matters. The IRS continually engages in enforcement actions ex post, after taxpayers have pursued transactions and claimed tax positions, such as by conducting audits or settlements. But it also frequently engages in actions ex ante, before taxpayers pursue transactions and claim tax positions, by issuing advance tax rulings to and entering into agreements with specific taxpayers. While current law appears to require public disclosure of certain types of ex ante tax administration, many forms of ex ante tax administration remain concealed from public view. This Article argues that documents related to a specific taxpayer’s tax affairs that reflect ex ante tax administration should be publicly accessible as a means of accountability, but that documents that reflect ex post tax actions should remain private in order to preserve effective tax enforcement. Further, this Article proposes that the public should have access not only to ex ante tax administration actions where the taxing authority grants taxpayers’ requests, but also to those actions where the taxing authority denies such requests, even if it does so without issuing an official written determination, a concept it defines as “dual tax transparency.”The Article then applies this analysis to several types of ex ante tax administration that are currently obscured by the curtain of tax privacy: withdrawn private letter ruling requests, adverse tax-exempt determination letters and advance pricing agreements. It concludes by exploring approaches to improving the accountability of the IRS regarding its ex post tax enforcement other than public disclosure of tax return information.