This book was written 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 this book 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. The findings are based ona 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...

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