Confronting Tax Havens, the Offshore Phenomenon, and Money Laundering 23 International Tax Journal 1997

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23 Int'l Tax J. 12 (1997)
Confronting Tax Havens, the Offshore Phenomenon, and Money Laundering

handle is hein.journals/intaxjo23 and id is 120 raw text is: Confronting Tax
Havens, the Offshore
Phenomenon, and
Money Laundering
RICHARD W. BARRET
Richard W. Barrett, JD, LLM, Taxation, University of Miami School of
Law, is an associate in the Chicago office of Bickel & Brewer, where he
specializes in tax litigation. The views expressed herein are those of the
author, not Bickel & Brewer.
T he United States has a serious problem-domestic and multina-
tional taxpayers are evading U.S. tax laws by moving large
sums of unreported income into offshore facilities and tax
havens.' The lost revenue costs the U.S. Treasury billions of
dollars annually.2
This article will provide a framework to understand the seriousness
of the offshore problem, the U.S. efforts to obtain financial records and
documents concerning international business transactions necessary to
prosecute such taxpayers, and procedures to protect the confidentiality of
targeted taxpayers.
THE OFFSHORE PROBLEM
The Gordon Report
International business transactions create problems for the Internal
Revenue Service because of the difficulty in tracking documentation and
1. See JP Springer, An Overview of International Evidence and Asset Gathering in Civil and
Criminal Tax Cases, 22 Geo Wash J Intl L & Econ (1988) 279.
2. Id.