Passing The Integrated Employer Test

Law360, New York (August 31, 2009, 1:16 PM EDT) -- When President Bush signed the Sarbanes-Oxley Act into law on July 30, 2002, he said it contained “the most far-reaching reforms of American business practices since the time of Franklin D. Roosevelt.”

As SOX enters its seventh anniversary, however, it has become clear that significant limitations exist where nonpublicly traded subsidiaries are concerned.

Indeed, it is now well-settled that the whistleblower protection provisions in Section 806 do not automatically apply to subsidiaries of publicly traded companies. But the exceptions to this rule have not been definitively...
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