Tax Havens and Their Use by United States Taxpayers

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Excerpt from Tax Havens and Their Use by United States Taxpayers: An Overview, A Report to the Commissioner of Internal Revenue, the Assistant Attorney General (Tax Division) And the Assistant Secretary of the Treasury (Tax Policy) This study was undertaken at the request of the Commissioner of Internal Revenue, the Assistant Attorney General (tax Division), and the Assistant Secretary of the Treasury (tax Policy). The purpose of the study was to develop an overview of tax havens and the use of tax havens by United States taxpayers. The study sought to determine the frequency and nature of tax haven transactions, identify specific types of tax haven transactions, obtain a description of the united States and foreign legal and regulatory environment in which tax haven transactions are conducted, describe Internal Revenue Service and Justice Department efforts to deal with tax haven related transactions, and to identify interagency coordination problems. Our findings are based on a review of judicial decisions and published literature in the field of international tax planning, research into internal irs documents concerning taxpayer activities, interviews with irs personnel, personnel who deal with tax haven issues for other Federal government agencies, and lawyers and certified public accountants who specialize in international taxation. Our findings are also based on a statistical analysis of available data concerning international banking, United States direct investment abroad, and foreign investment in the United States. While we cannot claim that we uncovered all of the methods employed to use tax havens, we believe that our inquiry was extensive enough to give us an understanding of the situation and to enable us to develop options which might be useful in improving the administration of the tax laws as they apply to tax havens. About the Publisher Forgotten Books publishes hundreds of thousands of rare and classic books. Find more at www.forgottenbooks.com This book is a reproduction of an important historical work. Forgotten Books uses state-of-the-art technology to digitally reconstruct the work, preserving the original format whilst repairing imperfections present in the aged copy. In rare cases, an imperfection in the original, such as a blemish or missing page, may be replicated in our edition. We do, however, repair the vast majority of imperfections successfully, any imperfections that remain are intentionally left to preserve the state of such historical works.