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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.

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