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Jeremy H. Temkin Jeremy H. Temkin

For more than a decade, the Department of Justice and Internal Revenue Service have devoted substantial resources to eradicating the use of offshore accounts to evade U.S. tax obligations. This column has chronicled these efforts, which have included criminal prosecutions and significant civil penalties imposed on taxpayers who failed to avail themselves of one of the IRS’s Offshore Voluntary Disclosure Programs. But the United States is not the only country whose citizens use offshore vehicles to cheat on their taxes, and while U.S. taxpayers think of Switzerland and Caribbean islands as tax havens, many foreign nationals use U.S.-based vehicles to evade their own tax obligations. A recent filing seeking “John Doe summonses” based upon a treaty request from Finland serves as a reminder that offshore tax evasion is not a uniquely American problem.

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