(1) Corporation li-cense tax returns on file with the department constitute public records but are open to inspection only upon the written and specific order of the governor. In the absence of such an order, neither a private individual nor a representative of another state department is entitled to inspect, to make, or to receive copies of any return on file with the department nor may the department disclose any information in its files relating to a particular taxpayer's return. When the governor issues an order permitting the inspection of a return or returns, the inspection must take place in the office of the department and the returns shall at all times remain in the custody of the department.

(2) Upon the presentation of satisfactory evidence of authorization, an officer or employee of a corporation or its attorney in fact may examine such corporation's returns and may secure copies thereof. The law expressly permits the commissioner of internal revenue or the proper officers of any state imposing a tax on or according to net income to inspect returns or to secure copies of returns or matter contained in any statement, affidavit, or certificate filed in connection with any return or any information disclosed by a report of investigation relating to the reported income, deductions, or tax liability of any corporation filing a return. However, such permission is granted subject to the condition that the statutes of the United States or the states grant substantially similar privileges to the proper officer of Montana charged with administration of the corporation license tax.