The Tennessee Court of Appeals had a brief discussion of an interesting question: Is piercing the corporate veil subject to the internal affairs doctrine? If so, then owners of Delaware corporations have strong protection against piercing. Delaware caselaw imposes a fairly high standard, probably requiring a showing of fraud, in piercing claims. In Boles v. National Development Co., the court held that piercing is not subject to the internal affairs doctrine because the underlying claim was on a Tennessee judgment, therefore Tennessee law should apply.