[Congressional Record Volume 153, Number 31 (Saturday, February 17, 2007)]
[Senate]
[Pages S2204-S2217]
From the Congressional Record Online through the Government Publishing Office [www.gpo.gov]
STATEMENTS ON INTRODUCED BILLS AND JOINT RESOLUTIONS
By Mrs. BOXER (for herself and Ms. Snowe):
S. 678. A bill to amend title 49, United States Code, to ensure air
passengers have access to necessary services while on a grounded air
carrier and are not unnecessarily held on a grounded air carrier before
or after a flight, and for other purposes; to the Committee on
Commerce, Science, and Transportation.
Mrs. BOXER. Mr. President, I rise today with my colleague Senator
Olympia Snowe to introduce ``The Airline Passenger Bill of Rights Act
of 2007,'' a bill which addresses an issue recently in the news--
airlines trapping passengers on the ground in delayed planes for hours
and hours without adequate food, water or bathrooms.
This week, at John F. Kennedy International Airport, a JetBlue
airplane sat on the tarmac for 11 hours. Over this New Year's Eve
weekend, American Airlines had to divert planes to Austin because of
the bad weather and one plane sat on the tarmac for nine hours.
For the passengers, the conditions were not good. There was not
enough food and potable water, and the bathrooms stopped working.
According to news reports, after waiting for five hours an elderly
woman asked for food and was told she could purchase a snack box for
$4.
This is unacceptable.
I have been stuck on the tarmac many times in my travel back and
forth to California. Weather delays are unavoidable, but airlines must
have a plan to ensure that their passengers--which often include
infants and the elderly--are not trapped on a plane for hours and
hours. If a plane is stuck on the tarmac or at the gate for hours, a
passenger should have the right to deplane. No one should be held
hostage on an aircraft when an airline can clearly find a way to get
passengers off safely.
This is not the first time that passengers have been trapped on an
airplane an extreme amount of time. In 1999, after a Northwest plane
was delayed on the tarmac for at least nine hours with the same poor
conditions, many Members of Congress were outraged and several
introduced comprehensive passenger bill of rights legislation.
While those bills did not become law, they had a powerful effect on
the airlines, which agreed to a 12-point ``Airline Customer Service
Plan.'' In the plan, the airlines committed to providing passengers
with better information about ticket prices and delays, better efforts
to retrieve lost luggage, fairer ``bumping'' policies and to meeting
essential needs during long on-aircraft delays. And since 1999 the
airlines have made improvements to passenger service.
But in recent years, as the industry has grown ever more competitive,
airlines are increasingly operating with no margin of error. Planes are
completely sold out, gates are continuously utilized, airport
facilities are stretched thin. This means that when bad weather hits,
the airlines can find themselves unable to readily accommodate delays
and cancellations. And the results, as we have seen this winter, can be
disastrous.
And that is why today we are introducing the ``Airline Passenger Bill
of Rights Act of 2007,'' commonsense legislation designed to ensure
that travelers can no longer be unnecessarily trapped on airplanes for
excessive periods of time or deprived of food, water or adequate
restrooms during a ground delay.
The legislation requires airlines to offer passengers the option of
safely leaving a plane they have boarded once
[[Page S2205]]
that plane has sat on the ground three hours after the plane door has
closed. This option would be provided every three hours that the plane
continues to sit on the ground.
The legislation also requires airlines to provide passengers with
necessary services such as food, potable water and adequate restroom
facilities while a plane is delayed on the ground.
The legislation provides two exceptions to the three-hour option. The
pilot may decide to not allow passengers to deplane if he or she
reasonably believes their safety or security would be at risk due to
extreme weather or other emergencies. Alternately, if the pilot
reasonably determines that the flight will depart within 30 minutes
after the three hour period, he or she can delay the deplaning option
for an additional 30 minutes.
I believe this legislation will do much to help consumers while
placing reasonable requirements on the airlines and I hope my
colleagues will support it.
______
By Ms. COLLINS (for herself, Mr. Lieberman, Mr. Coleman, Mr.
Carper, and Mrs. McCaskill):
S. 680. A bill to ensure proper oversight and accountability in
Federal contracting, and for other purposes; to the Committee on
Homeland Security and Governmental Affairs.
Ms. COLLINS. Mr. President. I rise to introduce the Accountability in
Government Contracting Act of 2007. This bill, which I am delighted is
cosponsored by Senators Lieberman, Coleman, Carper, and McCaskill, will
improve our stewardship of taxpayers' money by reforming contracting
practices, strengthening the procurement workforce, reforming our IG
community, and including other provisions to combat waste, fraud, and
abuse. It will also provide increased oversight and transparency in the
Federal Government's dealings with its contractors.
The Office of Federal Procurement Policy estimates that the Federal
Government purchased approximately $410 billion in goods and services
last year--more than a 50 percent increase in Federal purchases since
2001.
As the administration's proposed budget suggests, the costs of war,
natural disaster, homeland-security precautions, and other vital
programs will drive those expenditures to even higher levels in the
years ahead.
Each of us in this Chamber knows that the Federal Government's
prodigious purchasing can create abundant opportunities for fraud,
waste, and abuse. Whether the problem is purchases of unusable trailers
for hurricane victims, shoddy construction of schools and clinics in
Iraq, or abuse of purchase cards by Government employees, we must do a
better job of protecting taxpayer dollars and delivering better
acquisition outcomes.
Recognizing that imperative requires that we also recognize the
obstacles in our path. Such obstacles include resource constraints,
inexcusable rushes to award contracts, poor program administration, and
perverse incentives.
Other challenges to fair, effective, and open competition and
oversight include inadequate documentation requirements, overuse of
letter contracts that fail to include all the critical terms until
after performance is complete, excessive tiering of subcontractors, and
insufficient publicly available data on Federal contracts.
Too often, the problem of waste, fraud, and abuse stimulates floods
of outrage and magic-bullet proposals that lean more toward symbolic
gestures than practical reforms. The Accountability in Government
Contracting Act of 2007 confines itself to sensible, practical reforms
that will really make a difference.
Competition for Government contracts clearly helps to control costs,
encourage innovation, and keep contractors sharp. It is basic
economics--and it's the law, as Congress provided in the Competition in
Contracting Act of 1984. This bill promotes more open competition for
Government contracts--a positive step for both contractors and
taxpayers.
Unfortunately, the tide has been running the wrong way. Competition,
intended to produce savings, has sharply diminished. While the dollar
volume of Federal contracting has nearly doubled since the year 2000, a
recent report concluded that less than half of all ``contract
actions''--new contracts and payments against existing contracts--are
now subject to full and open competition: 48 percent in 2005, compared
to 79 percent in 2001. This is inexcusable.
The dangers inherent in sole-source contracting are on full display
in Iraq. For example, the Kellogg, Brown, and Root unit of Halliburton
designed and was awarded a multi-year sole-source contract for the
Restore Iraqi Oil project. A Defense Department audit concluded that
the firm later over-charged the government $61 million for fuel.
Incredibly, the Army Corps of Engineers permitted the overcharge.
According to a January 2007 Congressional Research Service report,
Kellogg, Brown, and Root's contract work in Iraq included billing for
$52 million to administer a project that entailed only $13 million in
actual project work, piping unpurified water into showers and laundries
used by our troops, and billing for 6 months of failure while using an
unsuitable technique to lay oil pipeline beneath a river.
As these examples suggest, we need more competition, less sole source
contracting, and tougher management in Federal contracts. The bill I
introduce today extends a practice adopted in the fiscal year 2002
Defense Authorization Act government-wide, mandating competition for
each task or delivery order over $100,000, the Simplified Acquisition
Threshold.
The bill would promote more informed and effective competition for
orders over $5 million by requiring more information in the statement
of work. At minimum, contractors would be given a clear statement of
agency requirements, a reasonable response period, and disclosure of
significant evaluation factors to be applied. For awards to be made on
a best-value rather than lowest-cost basis, the agency must provide a
written statement on the basis of the award and on the trade-off
between quality and cost.
To increase the quality of competitive bids, the bill mandates post-
award debriefings for task or delivery orders valued over $5 million.
Debriefings improve the transparency of the Federal acquisition process
by providing information that contractors can use to improve future
offers.
Competition helps secure good value for taxpayers' money, but there
are exceptions, and they should be the exception and not the rule, when
sole-source contracting is appropriate. Sole-source contracting
heightens the importance of effective oversight, but oversight is often
hampered by a lack of publicly available information on sole-source
contract awards.
The bill addresses that problem by requiring publication at the
``FedBizOpps'' website of notices of all sole-source task-or-delivery
orders above $100,000, within 10 business days after the award.
I shall note some other important provisions of the bill.
The bill will rein in the practice of awarding contracts missing key
terms, such as price, scope or schedule, and then failing to supply
those terms until the contractor delivers the good or service--thereby
placing all risk of failure on the government. In Iraq and Katrina
contracting, we saw the perils of failing to supply the ``missing
term'' promptly. For example, the Special Inspector General for Iraq
Reconstruction last July identified 194 individual task orders valued
at $3.4 billion that were classified as ``undefinitized contract
actions.''
This is entirely too much money and too many contract actions to
linger in this status. The bill corrects this flaw by requiring
contracting officers to unilaterally determine all missing terms, if
not mutually agreed upon, within 180 days or before 40 percent of the
work is performed, with the approval of the head of the contracting
agency, and subject to the contract disputes process.
Contracting for Hurricane Katrina and Iraq has also involved
excessive tiers of subcontractors, driving up costs and complicating
administration. The bill extends a tiering-control rule we placed in
the Department of Homeland Security appropriations bill, preventing
contractors from using subcontracts for more than 65 percent of the
cost of the contract, not including overhead and profit, unless the
head of agency determines that exceptional circumstances apply.
To further decrease the Government's reliance on large single-source
[[Page S2206]]
service contracts, the bill strengthens the preference for multiple
awards of Indefinite Delivery/Indefinite Quantity, or IDIQ, contracts
by prohibiting single awards of IDIQ contracts for services over $100
million. The Government would therefore have at least two contractors
for these large service contracts, who would then be required to
compete with each other for all task and/or delivery orders, unless
strict grounds for exceptions applied.
To ensure that agencies' increasing use of interagency contracting is
producing value, we require the Office of Federal Procurement Policy to
collect and make publicly available data on the numbers, scope, users,
and rationales for these contracts.
But increased competition will not solve all our ills. We must also
address the lack of personnel to award and administer Federal
contracts. We moved into the 21st century with 22 percent fewer Federal
civilian acquisition personnel than we had at the start of the 1990s.
The Department of Defense has been disbursing enormous amounts of money
to contractors since the first gulf war, but has reduced its
acquisition workforce by more than 50 percent from 1994 to 2005.
Among the current, attenuated Federal acquisition workforce, nearly
40 percent are eligible to retire by the end of this fiscal year.
Meanwhile, the number and scale of Federal purchases continue to rise,
making this human-capital crisis even more dire.
Therefore, the bill would help Federal agencies recruit, retain, and
develop an adequate acquisition workforce. Its mechanisms include
acquisition internship programs, promoting contracting careers, a
government-industry exchange program; an Acquisition Fellowship Program
with scholarships for graduate study, requirements for human-capital
strategic plans by chief acquisition officers, and a new senior-
executive-level position in the Office of Federal Procurement Policy to
manage this initiative.
In keeping with earlier Senate action, the bill also targets wasteful
use of purchase cards by seeking better analysis of purchase-card use
to identify fraud as well as potential savings, negotiate discounts,
collect and disseminate best practices, and address small-business
concerns in micro-purchases.
Such information is clearly necessary. In a hearing before the
Homeland Security and Governmental Affairs Committee, GAO detailed how
a FEMA employee provided his purchase card number to a vendor, who
agreed to provide the government 20 flat-bottom boats. Besides the
fact that FEMA agreed to pay $208,000 for the boats, about twice the
retail price, the vendor used the FEMA employee's purchase card
information to make two unauthorized transactions totaling about
$30,000. Neither the cardholder nor the approving official disputed the
unauthorized charges. As if this was not bad enough, FEMA failed to
gain title to the boats. It did not even enter 12 of the 20 boats into
their property system. Eventually, one of the boats was later found
back in the possession of the original owner.
The bill restricts the de-facto outsourcing of program-management
responsibility when a large contractor becomes a ``lead systems
integrator'' for a multi-part project. The bill requires OFPP to craft
a government-wide definition of lead systems integrators and study
their use by various agencies.
The bill also specifically addresses demonstrated problems in
contracting for assistance programs in Afghanistan. Numerous reports of
fraud, waste, and abuse in that country, such as the shockingly poor
construction of schools and clinics by the Louis Berger Group, echo the
findings of the SIGIR in Iraq.
The Louis Berger Group was awarded a contract to build schools and
clinics to help restore a decent life for the people of Afghanistan. Of
the 105 structures they erected before their work was stopped, 103
suffered roof collapses after the first snowfall. Here was a case that
combined a waste of taxpayer funds, damage to the U.S. image we were
trying to enhance, and an actual danger to the people we were trying to
help.
This bill requires the Administrator of USAID to revise the strategy
for the agency's assistance program in Afghanistan to include
measurable goals, specific time frames, resource levels, delineated
responsibilities, external factors bearing on success, and a schedule
for program evaluations. All of these things should have been done from
the outset, not after billions in Federal funds were expended.
Title II of the bill introduces targeted reforms of the Inspector
General system. IGs play a vital role in preventing and detecting
waste, fraud, and abuse. We must attract more of these specialists to
government service, and make the career attractive.
One vital provision in our bill might appear to run counter to that
aim but the provision, in fact, preserves the independence of our
Inspector Generals. It prohibits IGs from accepting any cash award or
cash bonus from the agency that they are auditing or investigating.
This codifies the honorable practice of most IGs of declining to accept
such awards because of the inherent conflict of interest they present.
The balancing mechanism for that prohibition is to increase the
salaries of Presidentially appointed IGs from Senior Executive Service
Level III to Level IV. This also corrects a common anomaly wherein
Deputy IGs collecting performance pay earn more than their supervising
IG. The bill removes the inequity and the disincentive to accepting a
promotion.
The bill makes other reforms that will increase the quality of IG
reports and audits. For example, it clarifies that IGs' subpoena power
extends to electronic documents. It also sets out professional
qualifications for the designated Federal entity IGs, or DFE IGs. These
IGs work in our smaller Federal agencies and are not subject to
confirmation. This is no excuse for this failure to supply minimum
professional qualifications for these important positions.
This bill also corrects a serious problem that has left millions of
fraudulently disbursed dollars un-recouped. Currently DFE IGs do not
have the power to institute lawsuits to recover claims under $150,000,
even if they have a compelling case. This is unacceptable. DFE IGs need
the power to pick this ``low hanging fruit,'' whose cumulative cost can
be huge. The bill corrects this problem by giving DFE IGs the same
authority that Presidentially appointed IGs have to investigate and
report false claims, and to recoup losses resulting from fraud below
$150,000.
I believe this summary shows how the Accountability in Government
Contracting Act of 2007 combines practical, workable, and targeted
reforms to improve a complex process that expends hundreds of billions
of taxpayer dollars every year. It will pay recurring dividends for
years to come in higher-quality proposals, in more efficiently
administered projects, and in better results for our citizens. I urge
my colleagues to support it.
______
By Mr. LEVIN (for himself, Mr. Coleman, and Mr. Obama):
S. 681. A bill to restrict the use offshore tax havens and abusive
tax shelters to inappropriately avoid Federal taxation, and for other
purposes; to the Committee on Finance.
Mr. LEVIN. Mr. President, offshore tax haven and tax shelter abuses
are undermining the integrity of our tax system, robbing the Treasury
of more than $100 billion each year, and shifting the tax burden from
high income persons and companies onto the backs of middle income
families. We can shut down a lot of these abuses if we have the
political will. That's why I am introducing today, along with Senators
Norm Coleman and Barack Obama, the Stop Tax Haven Abuse Act which
offers powerful new tools to do just that.
We all know there are billions of dollars in taxes that are owed but
not paid each year. It's called the tax gap. The latest estimate is
$345 billion in unpaid taxes each year owed by individuals,
corporations, and other organizations willing to rob Uncle Sam and
offload their tax burden onto the backs of honest taxpayers. We also
estimate that, of that $345 billion annual tax gap, offshore tax haven
abuses account for as much as $100 billion. Abusive tax shelters, both
domestic and offshore, account for additional billions in unpaid taxes
per year. To pay for critical needs, to avoid going even deeper into
debt, and to protect honest taxpayers, we must shut these abuses down.
[[Page S2207]]
The legislation we are introducing today is the product of years of
work by the Permanent Subcommittee on Investigations. I serve as
Chairman of that Subcommittee. Senator Coleman is the ranking
Republican, and Senator Obama is a valued Subcommittee member. Through
reports and hearings, the Subcommittee has worked for years to expose
and combat abusive tax havens and tax shelters. In the last Congress,
we confronted these twin threats to our treasury by introducing S.
1565, the Tax Shelter and Tax Haven Reform Act. Today's bill is an
improved version of that legislation, reflecting not only the
Subcommittee's additional investigative work but also innovative ideas
to end the use of tax havens and to stop unethical tax advisers from
aiding and abetting U.S. tax evasion.
A tax haven is a foreign jurisdiction that maintains corporate, bank,
and tax secrecy laws and industry practices that make it very difficult
for other countries to find out whether their citizens are using the
tax haven to cheat on their taxes. In effect, tax havens sell secrecy
to attract clients to their shores. They peddle secrecy the way other
countries advertise high quality services. That secrecy is used to
cloak tax evasion and other misconduct, and it is that offshore secrecy
that is targeted in our bill.
Abusive tax shelters are another target. Abusive tax shelters are
complicated transactions promoted to provide tax benefits unintended by
the tax code. They are very different from legitimate tax shelters,
such as deducting the interest paid on your home mortgage or
Congressionally approved tax deductions for building affordable
housing. Some abusive tax shelters involve complicated domestic
transactions; others make use of offshore shenanigans. All abusive tax
shelters are marked by one characteristic: there is no real economic or
business rationale other than tax avoidance. As Judge Learned Hand
wrote in Gregory v. Helvering, they are ``entered upon for no other
motive but to escape taxation.''
Abusive tax shelters are usually tough to prosecute. Crimes such as
terrorism, murder, and fraud produce instant recognition of the
immorality involved. Abusive tax shelters, by contrast, are often
``MEGOs,'' meaning ``My Eyes Glaze Over.'' Those who cook up these
concoctions count on their complexity to escape scrutiny and public
ire. But regardless of how complicated or eye-glazing, the hawking of
abusive tax shelters by tax professionals like accountants, bankers,
investment advisers, and lawyers to thousands of people like late-
night, cut-rate T.V. bargains is scandalous, and we need to stop it.
Hiding tax schemes through offshore companies and bank accounts in tax
havens with secrecy laws also needs to be stopped cold. It's up to
Congress to do just that.
Today, I would like to take some time to cut through the haze of
these schemes to describe them for what they really are and explain
what our bill would do to stop them. First, I will look at our
investigation into offshore tax havens and discuss the provisions we
have included in this bill to combat them. Then, I will turn to abusive
tax shelters and our proposed remedies.
For many years, the Permanent Subcommittee on Investigations has been
looking at the problem of offshore corporate, bank, and tax secrecy
laws and practices that help taxpayers dodge their U.S. tax obligations
by preventing U.S. tax authorities from gaining access to key financial
and beneficial ownership information. The Tax Justice Network, an
international non-profit organization dedicated to fighting tax
evasion, recently estimated that wealthy individuals worldwide have
stashed $11.5 trillion of their assets in offshore tax havens. At one
Subcommittee hearing, a former owner of an offshore bank in the Cayman
Islands testified that he believed 100 percent of his former bank
clients were engaged in tax evasion. He said that almost all were from
the United States and had taken elaborate measures to avoid IRS
detection of their money transfers. He also expressed confidence that
the offshore government that licensed his bank would vigorously defend
client secrecy in order to continue attracting business.
In a hearing held in August 2006, the Subcommittee released a staff
report with six case studies describing how U.S. individuals are using
offshore tax havens to evade U.S. taxes. In one case, two brothers from
Texas, Sam and Charles Wyly, established 58 offshore trusts and
corporations, and operated them for more than 13 years without alerting
U.S. authorities. To move funds abroad, the brothers transferred over
$190 million in stock option compensation they had received from U.S.
publicly traded companies to the offshore corporations. They claimed
that they did not have to pay tax on this compensation, because, in
exchange, the offshore corporations provided them with private
annuities which would not begin to make payments to them until years
later. In the meantime, the brothers directed the offshore corporations
to cash in the stock options and start investing the money. The
brothers failed to disclose these offshore stock transactions to the
SEC despite their position as directors and major shareholders in the
relevant companies.
The Subcommittee was able to trace more than $700 million in stock
option proceeds that the brothers invested in various ventures they
controlled, including two hedge funds, an energy company, and an
offshore insurance firm. They also used the offshore funds to purchase
real estate, jewelry, and artwork for themselves and their family
members, claiming they could use these offshore dollars to advance
their personal and business interests without having to pay any taxes
on the offshore income. The Wylys were able to carry on these tax
maneuvers in large part because all of their activities were shrouded
in offshore secrecy.
In another of the case histories, six U.S. taxpayers relied on
phantom stock trades between two offshore shell companies to generate
fake stock losses which were then used to shelter billions in income.
This offshore tax shelter scheme, known as the POINT Strategy, was
devised by Quellos, a U.S. securities firm headquartered in Seattle;
coordinated with a European financial firm known as Euram Advisers; and
blessed by opinion letters issued by two prominent U.S. law firms,
Cravath Swaine and Bryan Cave. The two offshore shell companies at the
center of the strategy, known as Jackstones and Barneville, supposedly
created a stock portfolio worth $9.6 billion. However, no cash or stock
transfers ever took place. Moreover, the shell companies that conducted
these phantom trades are so shrouded in offshore secrecy that no one
will admit to knowing who owns them. One of the taxpayers, Haim Saban,
used the scheme to shelter about $1.5 billion from U.S. taxes. Another,
Robert Wood Johnson IV, sought to shelter about $145 million. Both have
since agreed to settle with the IRS.
The persons examined by the Subcommittee are far from the only U.S.
taxpayers engaging in these types of offshore tax abuses. Recent
estimates are that U.S. individuals are using offshore tax schemes to
avoid payment of $40 to $70 billion in taxes each year.
Corporations are also using tax havens to avoid payment of U.S.
taxes. A recent IRS study estimates that U.S. corporations use offshore
tax havens to avoid about $30 billion in U.S. taxes each year. A GAO
report I released with Senator Dorgan in 2004 found that nearly two-
thirds of the top 100 companies doing business with the United States
government had one or more subsidiaries in a tax haven. One company,
Tyco International, had 115. Enron, in its heyday, had over 400 Cayman
subsidiaries.
Data released by the Commerce Department further demonstrates the
extent of U.S. corporate use of tax havens, indicating that, as of
200l, almost half of all foreign profits of U.S. corporations were in
tax havens. A study released by the journal Tax Notes in September 2004
found that American companies were able to shift $149 billion of
profits to 18 tax haven countries in 2002, up 68 percent from $88
billion in 1999.
Here's just one simplified example of the gimmicks being used by
corporations to transfer taxable income from the United States to tax
havens to escape taxation. Suppose a profitable U.S. corporation
establishes a shell corporation in a tax haven. The shell corporation
has no office or employees, just a mailbox address. The U.S. parent
[[Page S2208]]
transfers a valuable patent to the shell corporation. Then, the U.S.
parent and all of its subsidiaries begin to pay a hefty fee to the
shell corporation for use of the patent, reducing its U.S. income
through deducting the patent fees and thus shifting taxable income out
of the United States to the shell corporation. The shell corporation
declares a portion of the fees as profit, but pays no U.S. tax since it
is a tax haven resident. The icing on the cake is that the shell
corporation can then ``lend'' the income it has accumulated from the
fees back to the U.S. parent for its use. The parent, in turn, pays
``interest'' on the ``loans'' to the shell corporation, shifting still
more taxable income out of the United States to the tax haven. This
example highlights just a few of the tax haven ploys being used by some
U.S. corporations to escape paying their fair share of taxes here at
home.
Our Subcommittee's most recent investigation into offshore abuses
highlighted the extent to which offshore secrecy rules make it possible
for taxpayers to participate in illicit activity with little fear of
getting caught. Through a series of case studies, the Subcommittee
showed how U.S. taxpayers, with the help of offshore service providers,
financial institutions, and sometimes highly credentialed tax
professionals, set up entities in such secrecy jurisdictions as the
Isle of Man, the Cayman Islands, and the island of Nevis, claimed these
offshore entities were independent but, in fact, controlled them
through compliant offshore trustees, officers, directors, and corporate
administrators. Because of the offshore secrecy laws and practices,
these offshore service providers could and did go to extraordinary
lengths to protect their U.S. clients' identities and financial
information from U.S. tax and regulatory authorities, making it
extremely difficult, if not impossible, for U.S. law enforcement
authorities to get the information they need to enforce U.S. tax laws.
The extent of the offshore tax abuses documented by the Subcommittee
during this last year intensified our determination to find new ways to
combat offshore secrecy and restore the ability of U.S. tax enforcement
to pursue offshore tax cheats. I'd now like to describe the key
measures in the Stop Tax Havens Act being introduced today, which
includes the use of presumptions to overcome offshore secrecy barriers,
special measures to combat persons who impede U.S. tax enforcement, and
greater disclosure of offshore transactions.
Our last Subcommittee staff report provided six case histories
detailing how U.S. taxpayers are using offshore tax havens to avoid
payment of the taxes they owe. These case histories examined an
Internet based company that helps persons obtain offshore entities and
accounts; U.S. promoters that designed complex offshore structures to
hide client assets, even providing clients with a how-to manual for
going offshore; U.S. taxpayers who diverted business income offshore
through phony loans and invoices; a one-time tax dodge that deducted
phantom offshore stock losses from real U.S. stock income to shelter
that income from U.S. taxes; and the 13-year offshore empire built by
Sam and Charles Wyly. Each of these case histories presented the same
fact pattern in which the U.S. taxpayer, through lawyers, banks, or
other representatives, set up offshore trusts, corporations, or other
entities which had all the trappings of independence but, in fact, were
controlled by the U.S. taxpayer whose directives were implemented by
compliant offshore personnel acting as the trustees, officers,
directors or nominee owners of the offshore entities.
In the case of the Wylys, the brothers and their representatives
communicated Wyly directives to a so-called trust protector who then
relayed the directives to the offshore trustees. In the 13 years
examined by the Subcommittee, the offshore trustees never once rejected
a Wyly request and never once initiated an action without Wyly
approval. They simply did what they were told. A U.S. taxpayer in
another case history told the Subcommittee that the offshore personnel
who nominally owned and controlled his offshore entities, in fact,
always followed his directions, describing himself as the ``puppet
master'' in charge of his offshore holdings. When the Subcommittee
discussed these case histories with financial administrators from the
Isle of Man, they explained that none of the offshore personnel were
engaged in any wrongdoing, because their laws permit foreign clients to
transmit detailed, daily instructions to offshore service providers on
how to handle offshore assets, so long as it is the offshore trustee or
corporate officer who gives the final order to buy or sell the
assets. They explained that, under their law, an offshore entity is
considered legally independent from the person directing its activities
so long as that person follows the form of transmitting ``requests'' to
the offshore personnel who retain the formal right to make the
decisions, even though the offshore personnel always do as they are
asked.
The Subcommittee case histories illustrate what the tax literature
and law enforcement experience have shown for years: that the business
model followed in all offshore secrecy jurisdictions is for compliant
trustees, corporate administrators, and financial institutions to
provide a veneer of independence while ensuring that their U.S. clients
retain complete and unfettered control over ``their'' offshore assets.
That's the standard operating procedure offshore. Offshore service
providers pretend to own or control the offshore trusts, corporations,
and accounts they help establish, but what they really do is whatever
their clients tell them to do. In truth, the independence of offshore
entities is a legal fiction, and it is past time to pull back the
curtain on the reality hiding behind the legal formalities.
The reality behind these offshore practices makes a mockery of U.S.
laws that normally view trusts and corporations as independent
entities. They invite game-playing and tax evasion. To combat these
offshore abuses, our bill takes them head on in a number of ways.
The first section of our bill, Section 101, tackles this issue by
creating several rebuttable evidentiary presumptions that would strip
the veneer of independence from the U.S. person involved with offshore
entities, transactions, and accounts, unless that U.S. person presents
clear and convincing evidence to the contrary. These presumptions would
apply only in civil judicial or administrative tax or securities
enforcement proceedings examining transactions, entities, or accounts
in offshore secrecy jurisdictions. These presumptions would put the
burden of producing evidence from the offshore secrecy jurisdiction on
the taxpayer who chose to do business there, and who has access to the
information, rather than on the Federal Government which has little or
no practical ability to get the information. The creation of these
presumptions implements a bipartisan recommendation in the August 2006
Subcommittee report on tax haven abuses.
The bill would establish three evidentiary presumptions that could be
used in a civil tax enforcement proceeding: (1) a presumption that a
U.S. taxpayer who ``formed, transferred assets to, was a beneficiary
of, or received money or property'' from an offshore entity, such as a
trust or corporation, is in control of that entity; (2) a presumption
that funds or other property received from offshore are taxable income,
and that funds or other property transferred offshore have not yet been
taxed; and (3) a presumption that a financial account controlled by a
U.S. taxpayer in a foreign country contains enough money--$10,000--to
trigger an existing statutory reporting threshold and allow the IRS to
assert the minimum penalty for nondisclosure of the account by the
taxpayer.
In addition, the bill would establish two evidentiary presumptions
applicable to civil proceedings to enforce U.S. securities laws. One
would specify that if a director, officer, or major shareholder of a
U.S. publicly traded corporation were associated with an offshore
entity, that person would be presumed to control that offshore entity.
The second provides that securities nominally owned by an offshore
entity are presumed to be beneficially owned by any U.S. person who
controlled the offshore entity.
These presumptions are rebuttable, which means that the U.S. person
who is the subject of the proceeding could provide clear and convincing
evidence
[[Page S2209]]
to show that the presumptions were factually inaccurate. To rebut the
presumptions, a taxpayer could establish, for example, that an offshore
corporation really was controlled by an independent third party, or
that money sent from an offshore account really represented a
nontaxable gift instead of taxable income. If the taxpayer wished to
introduce evidence from a foreign person, such as an offshore banker,
corporate officer, or trust administrator, to establish those facts,
that foreign person would have to actually appear in the proceeding in
a manner that would permit cross examination in order for the taxpayer
to rebut the presumption. A simple affidavit from an offshore resident
who refused to submit to cross examination in the United States would
be insufficient.
There are several limitations on these presumptions to ensure their
operation is fair and reasonable. First, the evidentiary rules in
criminal cases would not be affected by this bill which would apply
only to civil proceedings. Second, because the presumptions apply only
in enforcement ``proceedings,'' they would not directly affect, for
example, a person's reporting obligations on a tax return or SEC
filing. The presumptions would come into play only if the IRS or SEC
were to challenge a matter in a formal proceeding. Third, the bill does
not apply the presumptions to situations where either the U.S. person
or the offshore entity is a publicly traded company, because in those
situations, even if a transaction were abusive, IRS and SEC officials
are generally able to obtain access to necessary information. Fourth,
the bill recognizes that certain classes of offshore transactions, such
as corporate reorganizations, may not present a potential for abuse,
and accordingly authorizes Treasury and the Securities and Exchange
Commission to issue regulations or guidance identifying such classes of
transactions, to which the presumptions would then not apply.
An even more fundamental limitation on the presumptions is that they
would apply only to transactions, accounts, or entities in offshore
jurisdictions with secrecy laws or practices that unreasonably restrict
the ability of the U.S. government to get needed information and which
do not have effective information exchange programs with U.S. law
enforcement. The bill requires the Secretary of the Treasury to
identify those offshore secrecy jurisdictions, based upon the practical
experience of the IRS in obtaining needed information from the relevant
country.
To provide a starting point for Treasury, the bill presents an
initial list of 34 offshore secrecy jurisdictions. This list is taken
from actual IRS court filings in numerous, recent court proceedings in
which the IRS sought permission to obtain information about U.S.
taxpayers active in the named jurisdictions. The bill thus identifies
the same jurisdictions that the IRS has already named publicly as
probable locations for U.S. tax evasion. Federal courts all over the
country have consistently found, when presented with the IRS list and
supporting evidence, that the IRS had a reasonable basis for concluding
that U.S. taxpayers with financial accounts in those countries
presented a risk of tax noncompliance. In every case, the courts
allowed the IRS to collect information about accounts and transactions
in the listed offshore jurisdictions.
The bill also provides Treasury with the authority to add or remove
jurisdictions from the initial list so that the list can change over
time and reflect the actual record of experience of the United States
in its dealings with specific jurisdictions around the world. The bill
provides two tests for Treasury to use in determining whether a
jurisdiction should be identified as an ``offshore secrecy
jurisdiction'' triggering the evidentiary presumptions: (1) whether the
jurisdiction's secrecy laws and practices unreasonably restrict U.S.
access to information, and (2) whether the jurisdiction maintains a tax
information exchange process with the United States that is effective
in practice.
If offshore jurisdictions make a decision to enact secrecy laws and
support industry practices furthering corporate, financial, and tax
secrecy, that's their business. But when U.S. taxpayers start using
those offshore secrecy laws and practices to evade U.S. taxes to the
tune of $100 billion per year, that's our business. We have a right to
enforce our tax laws and to expect that other countries will not help
U.S. tax cheats achieve their ends.
The aim of the presumptions created by the bill is to eliminate the
unfair advantage provided by offshore secrecy laws that for too long
have enabled U.S. persons to conceal their misconduct offshore and game
U.S. law enforcement. These presumptions would allow U.S. law
enforcement to establish what we all know from experience is normally
the case in an offshore jurisdiction--that a U.S. person associated
with an offshore entity controls that entity; that money and property
sent to or from an offshore entity involves taxable income; and that an
offshore account that wasn't disclosed to U.S. authorities should have
been. U.S. law enforcement can establish these facts presumptively,
without having to pierce the secrecy veil. At the same time, U.S.
persons who chose to transact their affairs through an offshore secrecy
jurisdiction are given the opportunity to lift the veil of secrecy and
demonstrate that the presumptions are factually wrong.
We believe these evidentiary presumptions will provide U.S. tax and
securities law enforcement with powerful new tools to shut down tax
haven abuses.
Section 102 of the bill is another innovative approach to combating
tax haven abuses. This section would build upon existing Treasury
authority to apply an array of sanctions to counter specific foreign
money laundering threats by extending that same authority to counter
specific foreign tax administration threats.
In 2001, the PATRIOT Act gave Treasury the authority under 31 U.S.C.
5318A to require domestic financial institutions and agencies to take
special measures with respect to foreign jurisdictions, financial
institutions, or transactions found to be of ``primary money laundering
concern.'' Once Treasury designates a foreign jurisdiction or financial
institution to be of primary money laundering concern, Section 5318A
allows Treasury to impose a range of requirements on U.S. financial
institutions in their dealings with the designated entity--from
requiring U.S. financial institutions, for example, to provide greater
information than normal about transactions involving the designated
entity, to prohibiting U.S. financial institutions from opening
accounts for that foreign entity.
This PATRIOT Act authority has been used sparingly, but to telling
effect. In some instances Treasury has employed special measures
against an entire country, such as Burma, to stop its financial
institutions from laundering funds through the U.S. financial system.
More often, however, Treasury has used the authority surgically,
against a single problem financial institution, to stop laundered funds
from entering the United States. The provision has clearly succeeded in
giving Treasury a powerful tool to protect the U.S. financial system
from money laundering abuses.
The bill would authorize Treasury to use that same tool to require
U.S. financial institutions to take the same special measures against
foreign jurisdictions or financial institutions found by Treasury to be
``impeding U.S. tax enforcement.'' Treasury could, for example, in
consultation with the IRS, Secretary of State, and the Attorney
General, require U.S. financial institutions that have correspondent
accounts for a designated foreign bank to produce information on all of
that foreign bank's customers. Alternatively, Treasury could prohibit
U.S. financial institutions from opening accounts for a designated
foreign bank, thereby cutting off that foreign bank's access to the
U.S. financial system. These types of sanctions could be as effective
in ending the worst tax haven abuses as they have been in curbing money
laundering.
In addition to extending Treasury's ability to impose special
measures against foreign entities impeding U.S. tax enforcement, the
bill would add one new measure to the list of possible sanctions that
could be applied to foreign entities: it would allow Treasury to
instruct U.S. financial institutions not to authorize or accept credit
card transactions involving the designated foreign jurisdiction or
financial institution. Denying tax haven banks the
[[Page S2210]]
ability to issue credit cards for use in the United States, for
example, would be a powerful new way to stop U.S. tax cheats from
obtaining access to funds hidden offshore.
Section 103 of the bill addresses another problem faced by the IRS in
cases involving offshore jurisdictions--completing audits in a timely
fashion when the evidence needed is located in a jurisdiction with
strict secrecy laws. Currently, in the absence of fraud or some other
exception, the IRS has 3 years from the date a return is filed to
complete an audit and assess any additional tax. Because offshore
secrecy laws slow down, and sometimes impede, efforts by the United
States to obtain offshore financial and beneficial ownership
information, the bill gives the IRS an extra 3 years to complete an
audit and assess a tax on transactions involving an offshore secrecy
jurisdiction. Of course, in the event that a case turns out to involve
actual fraud, this provision of the bill is not intended to limit the
rule giving the IRS unlimited time to assess tax in such cases.
Tax haven abuses are shrouded in secrecy. Section 104 attempts to
pierce that secrecy by creating two new disclosure mechanisms requiring
third parties to report on offshore transactions undertaken by U.S.
persons.
The first disclosure mechanism focuses on U.S. financial institutions
that open a U.S. account in the name of an offshore entity, such as an
offshore trust or corporation, and learn from an anti-money laundering
due diligence review, that a U.S. person is the beneficial owner behind
that offshore entity. In the Wyly case history examined by the
Subcommittee, for example, three major U.S. financial institutions
opened dozens of accounts for offshore trusts and corporations which
they knew were associated with the Wyly family.
Under current anti-money laundering law, all U.S. financial
institutions are supposed to know who is behind an account opened in
the name of, for example, an offshore shell corporation or trust. They
are supposed to obtain this information to safeguard the U.S. financial
system against misuse by terrorists, money launderers, and other
criminals.
Under current tax law, a bank or securities broker that opens an
account for a U.S. person is also required to give the IRS a 1099 form
reporting any capital gains earned on the account. However, the bank or
securities broker need not file a 1099 form if the account is owned by
a foreign entity not subject to U.S. tax law. Problems arise when an
account is opened in the name of an offshore entity that the bank or
broker knows, from its anti-money laundering review, is owned or
controlled by a U.S. person. The U.S. person should be filing a tax
return with the IRS reporting the income of the ``controlled foreign
corporation.'' However, since he or she knows it is difficult for the
IRS to connect an offshore accountholder to a particular taxpayer, he
or she may feel safe in not reporting that income. That complacency
might change, however, if the U.S. person knew that the bank or broker
who opened the account and learned of the connection had a legal
obligation to report any account income to the IRS.
Under current law, the way the regulations are written and typically
interpreted, the bank or broker can treat the foreign account holder as
an independent entity separate from the U.S. person, even if it knows
that the foreign corporation is merely holding title to the account for
the U.S. person, who exercises complete authority over the corporation
and benefits from any capital gains earned on the account. Current law
thus arguably imposes no duty on the bank or broker to file a 1099 form
disclosing the account to the IRS.
The bill would strengthen current law by expressly requiring a bank
or broker that knows, as a result of its anti-money laundering due
diligence or otherwise, that a U.S. person is the beneficial owner of a
foreign entity that opened the account, to disclose that account to the
IRS by filing a 1099 form reporting account income. This reporting
obligation would not require banks or brokers to gather any new
information--financial institutions are already required to perform
anti-money laundering due diligence for accounts opened by offshore
shell entities. The bill would instead require U.S. financial
institutions to act on what they already know by filing a 1099 form
with the IRS.
The second disclosure mechanism created by Section 104 targets U.S.
financial institutions that open foreign bank accounts or set up
offshore corporations, trusts, or other entities for their U.S.
clients. Our investigations have shown that it is common for private
bankers and brokers in the United States to provide these services to
their wealthy clients, so that the clients do not even need to leave
home to set up an offshore structure. The offshore entities can then
open both offshore and U.S. accounts and supposedly be treated as
foreign account holders for tax purposes.
A Subcommittee investigation learned, for example, that Citibank
Private Bank routinely offered to its clients private banking services
which included establishing one or more offshore shell corporations--
which it called Private Investment Corporations or PICs--in
jurisdictions like the Cayman Islands. The paperwork to form the PIC
was typically completed by a Citibank affiliate located in the
jurisdiction, such as Cititrust, which is a Cayman trust company.
Cititrust could then help the PIC open offshore accounts, while
Citibank could help the PIC open U.S. accounts.
Section 104 would require any U.S. financial institution that
directly or indirectly opens a foreign bank account or establishes a
foreign corporation or other entity for a U.S. customer to report that
action to the IRS. The bill authorizes the regulators of banks and
securities firms, as well as the IRS, to enforce this filing
requirement. Existing tax law already requires U.S. taxpayers that take
such actions to report them to the IRS, but many fail to do so, secure
in the knowledge that offshore secrecy laws limit the ability of the
IRS to find out about the establishment of new offshore accounts and
entities. That's why our bill turns to a third party--the financial
institution--to disclose the information. Placing this third party
reporting requirement on the private banks and brokers will make it
more difficult for U.S. clients to hide these transactions.
Section 105 of our bill strengthens the ability of the IRS to stop
offshore trust abuses by making narrow but important changes to the
Revenue Code provisions dealing with taxation of foreign trusts. The
rules on foreign trust taxation have been significantly strengthened
over the past 30 years to the point where they now appear adequate to
prevent or punish many of the more serious abuses. However, the
Subcommittee's 2006 investigation found a few loopholes that are still
being exploited by tax cheats and that need to be shut down.
The bill would make several changes to close these loopholes. First,
our investigation showed that U.S. taxpayers exercising control over a
supposedly independent foreign trust commonly used the services of a
liaison, called a trust ``protector'' or ``enforcer,'' to convey their
directives to the supposedly independent offshore trustees. A trust
protector is typically authorized to replace a foreign trustee at will
and to advise the trustees on a wide range of trust matters, including
the handling of trust assets and the naming of trust beneficiaries. In
cases examined by the Subcommittee, the trust protector was often a
friend, business associate, or employee of the U.S. person exercising
control over the foreign trust. Section 105 provides that, for tax
purposes, any powers held by a trust protector shall be attributed to
the trust grantor.
A second problem addressed by our bill involves U.S. taxpayers who
establish foreign trusts for the benefit of their families in an effort
to escape U.S. tax on the accumulation of trust income. Foreign trusts
can accumulate income tax free for many years. Previous amendments to
the foreign trust rules have addressed the taxation problem by
basically disregarding such trusts and taxing the trust income to the
grantors as it is earned. However, as currently written, this taxation
rule applies only to years in which the foreign trust has a named
``U.S. beneficiary.'' In response, to avoid the reach of the rule, some
taxpayers have begun structuring their foreign trusts so that they
operate with no named U.S. beneficiaries.
[[Page S2211]]
For example, the Subcommittee's investigation into the Wyly trusts
discovered that the foreign trust agreements had only two named
beneficiaries, both of which were foreign charities, but also gave the
offshore trustees ``discretion'' to name beneficiaries in the future.
The offshore trustees had been informed in a letter of wishes from the
Wyly brothers that the trust assets were to go to their children after
death. The trustees also knew that the trust protector selected by the
Wylys had the power to replace them if they did not comply with the
Wylys' instructions. In addition, during the life of the Wyly brothers,
and in accordance with instructions supplied by the trust protector,
the offshore trustees authorized millions of dollars in trust income to
be invested in Wyly business ventures and spent on real estate,
jewelry, artwork, and other goods and services used by the Wylys and
their families. The Wylys plainly thought they had found a legal
loophole that would let them enjoy and direct the foreign trust assets
without any obligation to pay taxes on the money they used.
To stop such foreign trust abuses, the bill would make it impossible
to pretend that this type of foreign trust has no U.S. beneficiaries.
The bill would shut down the loophole by providing that: (1) any U.S.
person actually benefiting from a foreign trust is treated as a trust
beneficiary, even if they are not named in the trust instrument; (2)
future or contingent U.S. beneficiaries are treated the same as current
beneficiaries; and (3) loans of foreign trust assets or property such
as real estate, jewelry and artwork (in addition to loans of cash or
securities already covered by current law) are treated as trust
distributions for tax purposes.
Section 106 of the bill takes aim at legal opinions that are used to
try to immunize taxpayers against penalties for tax shelter
transactions with offshore elements. The Subcommittee investigations
have found that tax practitioners sometimes tell potential clients that
they can invest in an offshore tax scheme without fear of penalty,
because they will be given a legal opinion that will shield the
taxpayer from any imposition of the 20 percent accuracy related
penalties in the tax code. Current law does, in fact, allow taxpayers
to escape these penalties if they can produce a legal opinion letter
stating that the tax arrangement in question is ``more likely than
not'' to survive challenge by the IRS. The problem with such opinions
where part of the transaction occurs in an offshore secrecy
jurisdiction is that critical assumptions of the opinions are often
based on offshore events, transactions and facts that are hidden and
cannot be easily ascertained by the IRS. Legal opinions based on such
assumptions should be understood by any reasonable person to be
inherently unreliable.
The bill therefore provides that, for any transaction involving an
offshore secrecy jurisdiction, the taxpayer would need to have some
other basis, independent of the legal opinion, to show that there was
reasonable cause to claim the tax benefit. The ``more likely than not''
opinion would no longer be sufficient in and of itself to shield a
taxpayer from all penalties if an offshore secrecy jurisdiction is
involved. This provision, which is based upon a suggestion made by IRS
Commissioner Mark Everson at our August hearing, is intended to force
taxpayers to think twice about entering into an offshore scheme and to
stop thinking that an opinion by a lawyer is all they need to escape
any penalty for nonpayment of taxes owed. By making this change, we
would also provide an incentive for taxpayers to understand and
document the complete facts of the offshore aspects of a transaction
before claiming favorable tax treatment.
To ensure that this section does not impede legitimate business
arrangements in offshore secrecy jurisdictions, the bill authorizes the
Treasury Secretary to issue regulations exempting two types of legal
opinions from the application of this section. First, the Treasury
Secretary could exempt all legal opinions that have a confidence level
substantially above the more-likely-than-not level, such as opinions
which express confidence that a proposed tax arrangement ``should''
withstand an IRS challenge. ``More-likely-than-not'' opinion letters
are normally viewed as expressing confidence that a tax arrangement has
at least a 50 percent chance of surviving IRS review, while a
``should'' opinion is normally viewed as expressing a confidence level
of 70 to 75 percent. This first exemption is intended to ensure that
legal opinions on arrangements that are highly likely to survive IRS
review would continue to shield taxpayers from the 20 percent penalty.
Second, the Treasury Secretary could exempt legal opinions addressing
classes of transactions, such as corporate reorganizations, that do not
present the potential for abuse. These exemptions would ensure that
taxpayers who obtain legal opinions for these classes of transactions
would also be protected from tax code penalties.
In addition to tax abuses, last year's Subcommittee investigation of
the Wyly case history uncovered a host of troubling transactions
involving U.S. securities held by the 58 offshore trusts and
corporations associated with the two Wyly brothers. The offshore
entities had obtained these securities by exercising about $190 million
in stock options provided to them by the Wylys. The Wylys had obtained
these stock options as compensation from three U.S. publicly traded
corporations at which they were directors and major shareholders.
The investigation found that the Wylys generally did not report the
offshore entities' stock holdings or transactions in their SEC filings,
on the ground that the 58 offshore trusts and corporations functioned
as independent entities, even though the Wylys continued to direct the
entities' investment activities. The public companies where the Wylys
were corporate insiders also failed to include in their SEC filings
information about the company shares held by the offshore entities,
even though the companies knew of their close relationship to the
Wylys, that the Wylys had provided the offshore entities with
significant stock options, and that the offshore entities held large
blocks of the company stock. On other occasions, the public companies
and various financial institutions failed to treat the shares held by
the offshore entities as affiliated stock, even though they were aware
of the offshore entities' close association with the Wylys. The
investigation also found that, because both the Wylys and the public
companies had failed to disclose the holdings of the offshore entities,
for l3 years federal regulators were unaware of those holdings and the
relationships between the offshore entities and the Wyly brothers.
Corporate insiders and public companies are already obligated by
current law to disclose share holdings and transactions of offshore
entities affiliated with a company director, officer, or major
shareholder. Current penalties, however, appear insufficient to ensure
compliance in light of the low likelihood that U.S. authorities will
learn what went on in an offshore jurisdiction. To address this
problem, our bill would establish a new monetary penalty of up to $1
million for persons who knowingly fail to disclose offshore holdings
and transactions in violation of U.S. securities laws.
The Subcommittee's August 2006 investigation showed that the Wyly
brothers used two hedge funds and a private equity fund controlled by
them to funnel millions of untaxed offshore dollars into U.S.
investments. In addition, that and earlier investigations provide
extensive evidence on the role played by U.S. company formation agents
in assisting U.S. persons to set up offshore structures. Moreover, a
Subcommittee hearing in November 2006 disclosed that U.S. company
formation agents are forming U.S. shell companies for numerous
unidentified foreign clients. Some of those U.S. shell companies were
later used in illicit activities, including money laundering, terrorist
financing, drug crimes, tax evasion, and other misconduct. Because
hedge funds, private equity funds, and company formation agents are as
vulnerable as other financial institutions to money launderers seeking
entry into the U.S. financial system, the bill contains two provisions
aimed at ensuring that these groups know their clients and do not
accept or transmit suspect funds into the U.S. financial system.
Currently, unregistered investment companies, such as hedge funds and
private equity funds, are the only class of financial institutions
under the Bank Secrecy Act that transmit substantial offshore funds
into the United
[[Page S2212]]
States, yet are not required by law to have anti-money laundering
programs, including Know Your Customer, due diligence procedures. There
is no reason why this growing sector of our financial services industry
should continue to serve as a gateway into the U.S. financial system
for monies of unknown origin. The Treasury Department proposed anti-
money laundering regulations for these groups in 2002, but has not yet
finalized them, even though the principal hedge fund trade association
supports the issuance of federal anti-money laundering regulations. Our
bill would require Treasury to issue final regulations within 180 days
of the enactment of the bill. Treasury would be free to work from its
existing proposal, but the bill would also require the final
regulations to direct hedge funds and private equity funds to exercise
due diligence before accepting offshore funds and to comply with the
same procedures as other financial institutions if asked by federal
regulators to produce records kept offshore.
In addition, the bill would add company formation agents to the list
of persons subject to the anti-money laundering obligations of the Bank
Secrecy Act. For the first time, those engaged in the business of
forming corporations and other entities, both offshore and in the 50
States, would be responsible for knowing the identity of the person for
whom they are forming the entity. The bill also directs Treasury to
develop anti-money laundering regulations for this group. Treasury's
key anti-money laundering agency, the Financial Crimes Enforcement
Network, testified before the Subcommittee that it was considering
drafting such regulations.
We expect and intend that, as in the case of all other entities
covered by the Bank Secrecy Act, the regulations issued in response to
this bill would instruct hedge funds, private equity funds, and company
formation agents to adopt risk-based procedures that would concentrate
their due diligence efforts on clients that pose the highest risk of
money laundering.
Section 204 of the bill focuses on one tool used by the IRS in recent
years to uncover taxpayers involved in offshore tax schemes, known as
John Doe summonses. The bill would make three technical changes to IRS
rules governing the issuance of these summonses to make their use more
effective in offshore and other complex investigations.
A John Doe summons is an administrative IRS summons used to request
information in cases where the identity of a taxpayer is unknown. In
cases involving known taxpayers, the IRS may issue a summons to a third
party to obtain information about a U.S. taxpayer, but must also notify
the taxpayer who then has 20 days to petition a court to quash the
summons to the third party. With a John Doe summons, however, IRS does
not have the taxpayer's name and does not know where to send the
taxpayer notice, so the statute substitutes a procedure in which the
IRS must apply to a court for advance permission to serve the summons
on the third party. To obtain approval of the summons, the IRS must
show the court, in public filings to be resolved in open court, that:
(1) the summons relates to a particular person or ascertainable class
of persons, (2) there is a reasonable basis for concluding that there
is a tax compliance issue involving that person or class of persons,
and (3) the information sought is not readily available from other
sources.
In recent years, the IRS has used John Doe summonses to obtain
information about taxpayers operating in offshore secrecy
jurisdictions. For example, the IRS has obtained court approval to
issue John Doe summonses to credit card associations, credit card
processors, and credit card merchants, to obtain information about
taxpayers using credit cards issued by offshore banks. This information
has led to many successful cases in which the IRS identified funds
hidden offshore and recovered unpaid taxes.
Use of the John Doe summons process, however, has proved
unnecessarily time consuming and expensive. For each John Doe summons
involving an offshore secrecy jurisdiction, the IRS has had to
establish in court that the involvement of accounts and transactions in
offshore secrecy jurisdictions meant there was a significant likelihood
of tax compliance problems. To relieve the IRS of the need to make this
same proof over and over, the bill would provide that, in any John Doe
summons proceeding involving a class defined in terms of accounts or
transactions in an offshore secrecy jurisdiction, the court may presume
that the case raises tax compliance issues. This presumption would then
eliminate the need for the IRS to repeatedly establish in court the
obvious fact that accounts, entities, and transactions involving
offshore secrecy jurisdictions raise tax compliance issues.
Second, for a smaller subset of John Doe cases, where the only
records sought by the IRS are offshore bank account records held by a
U.S. financial institution where the offshore bank has an account, the
bill would relieve the IRS of the obligation to get prior court
approval to serve the summons. Again, the justification is that
offshore bank records are highly likely to involve accounts that raise
tax compliance issues so no prior court approval should be required.
Even in this instance, however, if a U.S. financial. institution were
to decline to produce the requested records, the IRS would have to
obtain a court order to enforce the summons.
Finally, the bill would streamline the John Doe summons approval
process in large ``project'' investigations where the IRS anticipates
issuing multiple summonses to definable classes of third parties, such
as banks or credit card associations, to obtain information related to
particular taxpayers. Right now, for each summons issued in connection
with a project, the IRS has to obtain the approval of a court, often
having to repeatedly establish the same facts before multiple judges in
multiple courts. This repetitive exercise wastes IRS, Justice
Department, and court resources, and fragments oversight of the overall
IRS investigative effort.
To streamline this process and strengthen court oversight of IRS use
of John Doe summons, the bill would authorize the IRS to present an
investigative project, as a whole, to a single judge to obtain approval
for issuing multiple summons related to that project. In such cases,
the court would retain jurisdiction over the case after approval is
granted, to exercise ongoing oversight of IRS issuance of summonses
under the project. To further strengthen court oversight, the IRS would
be required to file a publicly available report with the court on at
least an annual basis describing the summonses issued under the
project. The court would retain authority to restrict the use of
further summonses at any point during the project. To evaluate the
effectiveness of this approach, the bill would also direct the
Government Accountability Office to report on the use of the provision
after five years.
Finally, Section 205 of the bill would make several changes to Title
31 of the U.S. Code needed to reflect the IRS's new responsibility for
enforcing the Foreign Bank Account Report (FBAR) requirements and to
clarify the right of access to Suspicious Activity Reports by IRS civil
enforcement authorities.
Under present law, a person controlling a foreign financial account
with over $10,000 is required to check a box on his or her income tax
return and, under Title 31, also file an FBAR form with the IRS.
Treasury's Financial Crimes Enforcement Network (FinCEN), which
normally enforces Title 31 provisions, recently delegated to the IRS
the responsibility for investigating FBAR violations and assessing FBAR
penalties. Because the FBAR enforcement jurisdiction derives from Title
31, however, and most of the information available to the IRS is tax
return information, IRS routinely encounters difficulties in using
available tax information to fulfill its new role as FBAR enforcer. The
tax disclosure law permits the use of tax information only for the
administration of the internal revenue laws or ``related statutes.''
This rule is presently understood to require the IRS to determine, at a
managerial level and on a case by case basis, that the Title 31 FBAR
law is a ``related statute.'' Not only does this necessitate repetitive
determinations in every FBAR case investigated by the IRS before each
agent can look at the potential non-filer's income tax return, but it
prevents the use by IRS
[[Page S2213]]
of bulk data on foreign accounts received from tax treaty partners to
compare to FBAR filing records to find non-filers.
One of the stated purposes for the FBAR filing requirement is that
such reports ``have a high degree of usefulness in . . . tax . . .
investigations or proceedings.'' 31 U. S. C 5311. If one of the reasons
for requiring taxpayers to file FBARs is to use the information for tax
purposes, and if IRS is to be charged with FBAR enforcement because of
the FBARs' connection to taxes, common sense dictates that the FBAR
statute should be considered a related statute for tax disclosure
purposes, and the bill changes the related statute rule to say that.
The second change made by Section 205 is a technical amendment to the
wording of the penalty provision. Currently the penalty is determined
in part by the balance in the foreign bank account at the time of the
``violation.'' The violation is interpreted to have occurred on the due
date of the FBAR return, which is June 30 of the year following the
year to which the report relates. The statute's use of this specific
June 30th date can lead to strange results if money is withdrawn from
the foreign account after the reporting period closed but before the
return due date. To eliminate this unintended problem, the bill would
instead gauge the penalty by using the highest balance in the account
during the reporting period.
The third part of section 205 relates to Suspicious Activity Reports,
which financial institutions are required to file with FinCEN whenever
they encounter suspicious transactions. FinCEN is required to share
this information with law enforcement, but currently does not permit
IRS civil investigators access to the information. However, if the
information that is gathered and transmitted to Treasury by the
financial institutions at great expense is to be effectively utilized,
its use should not be limited to the relatively small number of
criminal investigators, who can barely scratch the surface of the large
number of reports. In addition, sharing the information with civil tax
investigators would not increase the risk of disclosure, because they
operate under the same tough disclosure rules as the criminal
investigators. In some cases, IRS civil agents are now issuing an IRS
summons to a financial institution to get access, for a production fee,
to the very same information the financial institution has already
filed with Treasury in a SAR. The bill changes those anomalous results
by making it clear that ``law enforcement'' includes civil tax law
enforcement.
Overall, our bill includes a host of innovative measures to
strengthen the ability of Federal regulators to combat offshore tax
haven abuses. We believe these new tools merit Congressional attention
and enactment this year if we are going to begin to make a serious dent
in the $100 billion in annual lost tax revenue from offshore tax abuses
that forces honest taxpayers to shoulder a greater tax burden than they
would otherwise have to bear.
Until now, I've been talking about what the bill would do to combat
offshore tax abuses. Now I want to turn to what the bill would do to
combat abusive tax shelters and their promoters who use both domestic
and offshore means to achieve their ends. Most of these provisions
appeared in the Levin-Coleman-Obama bill from the last Congress. Some
provisions from that bill have been dropped or modified in light of
those that were enacted into law.
For five years, the Permanent Subcommittee on Investigations has been
conducting investigations into the design, sale, and implementation of
abusive tax shelters. Our first hearing on this topic in recent years
was held in January 2002, when the Subcommittee examined an abusive tax
shelter purchased by Enron. In November 2003, the Subcommittee held two
days of hearings and released a staff report that pulled back the
curtain on how even some respected accounting firms, banks, investment
advisors, and law firms had become engines pushing the design and sale
of abusive tax shelters to corporations and individuals across this
country. In February 2005, the Subcommittee issued a bipartisan report
that provided further details on the role these professional firms
played in the proliferation of these abusive shelters. Our Subcommittee
report was endorsed by the full Committee on Homeland Security and
Governmental Affairs in April 2005. Most recently, a 2006 Subcommittee
staff report entitled, ``Tax Haven Abuses: The Enablers, the Tools, and
Secrecy,'' disclosed how financial and legal professionals designed and
sold yet another abusive tax shelter known as the POINT Strategy, which
depended on secrecy laws and practices in the Isle of Man to conceal
the phantom nature of securities trades that lay at the center of this
tax shelter transaction.
The Subcommittee investigations have found that many abusive tax
shelters are not dreamed up by the taxpayers who use them. Instead,
most are devised by tax professionals, such as accountants, bankers,
investment advisors, and lawyers, who then sell the tax shelter to
clients for a fee. In fact, as our 2003 investigation widened, we found
a large number of tax advisors cooking up one complex scheme after
another, packaging them up as generic ``tax products'' with boiler-
plate legal and tax opinion letters, and then undertaking elaborate
marketing schemes to peddle these products to literally thousands of
persons across the country. In return, these tax shelter promoters were
getting hundreds of millions of dollars in fees, while diverting
billions of dollars in tax revenues from the U.S. Treasury each year.
For example, one shelter investigated by the Subcommittee and
featured in the 2003 hearings has since become part of an IRS effort to
settle cases involving a set of abusive tax shelters known as ``Son of
Boss.'' Following our hearing, more than 1,200 taxpayers have admitted
wrongdoing and agreed to pay back taxes, interest and penalties
totaling more than $3.7 billion. That's billions of dollars the IRS has
collected on just one type of tax shelter, demonstrating both the depth
of the problem and the potential for progress. The POINT shelter
featured in our 2006 hearing involved another $300 million in tax loss
on transactions conducted by just six taxpayers.
The bill we are introducing today contains a number of measures to
curb abusive tax shelters. First, it would strengthen the penalties
imposed on those who aid or abet tax evasion. Second, it would prohibit
the issuance of tax shelter patents. Several provisions would deter
bank participation in abusive tax shelter activities by requiring
regulators to develop new examination procedures to detect and stop
such activities. Others would end outdated communication barriers
between the IRS and other enforcement agencies such as the SEC, bank
regulators, and the Public Company Accounting Oversight Board, to allow
the exchange of information relating to tax evasion cases. The bill
also provides for increased disclosure of tax shelter information to
Congress.
In addition, the bill would simplify and clarify an existing
prohibition on the payment of fees linked to tax benefits; and
authorize Treasury to issue tougher standards for tax shelter opinion
letters. Finally, the bill would codify and strengthen the economic
substance doctrine, which eliminates tax benefits for transactions that
have no real business purpose apart from avoiding taxes.
Let me be more specific about these key provisions to curb abusive
tax shelters.
Title III of the bill strengthens two very important penalties that
the IRS can use in its fight against the professionals who make complex
abusive shelters possible. Three years ago, the penalty for promoting
an abusive tax shelter, as set forth in Section 6700 of the tax code,
was the lesser of $1,000 or 100 percent of the promoter's gross income
derived from the prohibited activity. That meant in most cases the
maximum fine was just $1,000.
Many abusive tax shelters sell for $100,000 or $250,000 apiece. Our
investigation uncovered some tax shelters that were sold for as much as
$2 million or even $5 million apiece, as well as instances in which the
same cookie-cutter tax opinion letter was sold to 100 or even 200
clients. There are huge profits to be made in this business, and a
$1,000 fine is laughable.
The Senate acknowledged that in 2004 when it adopted the Levin-
Coleman amendment to the JOBS Act, S. 1637, raising the Section 6700
penalty
[[Page S2214]]
on abusive tax shelter promoters to 100 percent of the fees earned by
the promoter from the abusive shelter. A 100 percent penalty would have
ensured that the abusive tax shelter hucksters would not get to keep a
single penny of their ill-gotten gains. That figure, however, was cut
in half in the conference report, setting the penalty at 50 percent of
the fees earned and allowing the promoters of abusive shelters to keep
half of their illicit profits.
While a 50 percent penalty is an obvious improvement over $1000, this
penalty still is inadequate and makes no sense. Why should anyone who
pushes an illegal tax shelter that robs our Treasury of needed revenues
get to keep half of his ill-gotten gains? What deterrent effect is
created by a penalty that allows promoters to keep half of their fees
if caught, and of course, all of their fees if they are not caught?
Effective penalties should make sure that the peddler of an abusive
tax shelter is deprived of every penny of profit earned from selling or
implementing the shelter and then is fined on top of that. Section 301
of this bill would do just that by increasing the penalty on tax
shelter promoters to an amount equal to up to 150 percent of the
promoters' gross income from the prohibited activity.
A second penalty provision in the bill addresses what our
investigations have found to be a key problem: the knowing assistance
of accounting firms, law firms, banks, and others to help taxpayers
understate their taxes. In addition to those who meet the definition of
``promoters'' of abusive shelters, there are professional firms that
aid and abet the use of abusive tax shelters and enable taxpayers to
carry out the abusive tax schemes. For example, law firms are often
asked to write ``opinion letters'' to help taxpayers head off IRS
questioning and fines that they might otherwise confront for using an
abusive shelter. Currently, under Section 6701 of the tax code, these
aiders and abettors face a maximum penalty of only $1,000, or $10,000
if the offender is a corporation. This penalty, too, is a joke. When
law firms are getting $50,000 for each of these cookie-cutter
opinion letters, it provides no deterrent whatsoever. A $1,000 fine is
like a jaywalking ticket for robbing a bank.
Section 302 of the bill would strengthen Section 6701 significantly,
subjecting aiders and abettors to a maximum fine up to 150 percent of
the aider and abettor's gross income from the prohibited activity. This
penalty would apply to all aiders and abettors, not just tax return
preparers.
Again, the Senate has recognized the need to toughen this critical
penalty. In the 2004 JOBS Act, Sen. Coleman and I successfully
increased this fine to 100 percent of the gross income derived from the
prohibited activity. Unfortunately, the conference report completely
omitted this change, allowing aiders and abettors to continue to profit
without penalty from their wrongdoing.
If further justification for toughening these penalties is needed,
one document uncovered by our investigation shows the cold calculation
engaged in by a tax advisor facing low fines. A senior tax professional
at accounting giant KPMG compared possible tax shelter fees with
possible tax shelter penalties if the firm were caught promoting an
illegal tax shelter. This senior tax professional wrote the following:
``[O]ur average deal would result in KPMG fees of $360,000 with a
maximum penalty exposure of only $31,000.'' He then recommended the
obvious: going forward with sales of the abusive tax shelter on a cost-
benefit basis.
Section 303 of our bill addresses the growing problem of tax shelter
patents, which has the potential for significantly increasing abusive
tax shelter activities.
In 1998, a Federal appeals court ruled for the first time that
business methods can be patented and, since then, various tax
practitioners have filed applications to patent a variety of tax
strategies. The U.S. Patent Office has apparently issued 49 tax
strategy patents to date, with more on the way. These patents were
issued by patent officers who, by statute, have a background in science
and technology, not tax law, and know little to nothing about abusive
tax shelters.
Issuing these types of patents raises multiple public policy
concerns. Patents issued for aggressive tax strategies, for example,
may enable unscrupulous promoters to claim the patent represents an
official endorsement of the strategy and evidence that it would
withstand IRS challenge. Patents could be issued for blatantly illegal
tax shelters, yet remain in place for years, producing revenue for the
wrongdoers while the IRS battles the promoters in court. Patents for
tax shelters found to be illegal by a court would nevertheless remain
in place, creating confusion among users and possibly producing illicit
income for the patent holder.
Another set of policy concerns relates to the patenting of more
routine tax strategies. If a single tax practitioner is the first to
discover an advantage granted by the law and secures a patent for it,
that person could then effectively charge a toll for all other
taxpayers to use the same strategy, even though as a matter of public
policy all persons ought to be able to take advantage of the law to
minimize their taxes. Companies could even patent a legal method to
minimize their taxes and then refuse to license that patent to their
competitors in order to prevent them from lowering their operating
costs. Tax patents could be used to hinder productivity and competition
rather than foster it.
The primary rationale for granting patents is to encourage
innovation, which is normally perceived to be a sufficient public
benefit to justify granting a temporary monopoly to the patent holder.
In the tax arena, however, there has historically been ample incentive
for innovation in the form of the tax savings alone. The last thing we
need is a further incentive for aggressive tax shelters. That's why
Section 303 would prohibit the patenting of any ``invention designed to
minimize, avoid, defer, or otherwise affect the liability for Federal,
State, local, or foreign tax.''
Another finding of the Subcommittee investigations is that some tax
practitioners are circumventing current state and federal constraints
on charging tax service fees that are dependent on the amount of
promised tax benefits. Traditionally, accounting firms charged flat
fees or hourly fees for their tax services. In the 1990s, however, they
began charging ``value added'' fees based on, in the words of one
accounting firm's manual, ``the value of the services provided, as
opposed to the time required to perform the services.'' In addition,
some firms began charging ``contingent fees'' that were calculated
according to the size of the paper ``loss'' that could be produced for
a client and used to offset the client's other taxable income the
greater the so-called loss, the greater the fee.
In response, many states prohibited accounting firms from charging
contingent fees for tax work to avoid creating incentives for these
firms to devise ways to shelter substantial sums. The SEC and the
American Institute of Certified Public Accountants also issued rules
restricting contingent fees, allowing them in only limited
circumstances. Recently, the Public Company Accounting Oversight Board
issued a similar rule prohibiting public accounting firms from charging
contingent fees for tax services provided to the public companies they
audit. Each of these federal, state, and professional ethics rules
seeks to limit the use of contingent fees under certain, limited
circumstances.
The Subcommittee investigation found that tax shelter fees, which are
typically substantial and sometimes exceed $1 million, are often linked
to the amount of a taxpayer's projected paper losses which can be used
to shelter income from taxation. For example, in four tax shelters
examined by the Subcommittee in 2003, documents show that the fees were
equal to a percentage of the paper loss to be generated by the
transaction. In one case, the fees were typically set at 7 percent of
the transaction's generated ``tax loss'' that clients could use to
reduce other taxable income. In another, the fee was only 3.5 percent
of the loss, but the losses were large enough to generate a fee of over
$53 million on a single transaction. In other words, the greater the
loss that could be concocted for the taxpayer or ``investor,'' the
greater the profit for the tax promoter. Think about that--greater the
loss, the greater the profit. How's that for turning capitalism on its
head!
In addition, evidence indicated that, in at least one instance, a tax
advisor
[[Page S2215]]
was willing to deliberately manipulate the way it handled certain tax
products to circumvent contingent fee prohibitions. An internal
document at an accounting firm related to a specific tax shelter, for
example, identified the states that prohibited contingent fees. Then,
rather than prohibit the tax shelter transactions in those states or
require an alternative fee structure, the memorandum directed the
firm's tax professionals to make sure the engagement letter was signed,
the engagement was managed, and the bulk of services was performed ``in
a jurisdiction that does not prohibit contingency fees.''
Right now, the prohibitions on contingent fees are complex and must
be evaluated in the context of a patchwork of federal, state, and
professional ethics rules. Section 304 of the bill would establish a
single enforceable rule, applicable nationwide, that would prohibit tax
practitioners from charging fees calculated according to a projected or
actual amount of tax savings or paper losses.
The bill would also help fight abusive tax shelters that are
disguised as complex investment opportunities and use financing or
securities transactions provided by financial institutions. In reality,
tax shelter schemes lack the economic risks and rewards associated with
a true investment. These phony transactions instead often rely on the
temporary use of significant amounts of money in low risk schemes
mischaracterized as real investments. The financing or securities
transactions called for by these schemes are often supplied by a bank,
securities firm, or other financial institution.
Currently the tax code prohibits financial institutions from
providing products or services that aid or abet tax evasion or that
promote or implement abusive tax shelters. The agencies that oversee
these financial institutions on a daily basis, however, are experts in
banking and securities law and generally lack the expertise to spot tax
issues. Section 305 would crack down on financial institutions' illegal
tax shelter activities by requiring federal bank regulators and the SEC
to work with the IRS to develop examination techniques to detect such
abusive activities and put an end to them.
These examination techniques would be used regularly, preferably in
combination with routine regulatory examinations, and the regulators
would report potential violations to the IRS. The agencies would also
be required to prepare joint reports to Congress in 2009 and 2012 on
preventing the participation of financial institutions in tax evasion
or tax shelter activities.
During hearings before the Permanent Subcommittee on Investigations
on tax shelters in November 2003, IRS Commissioner Everson testified
that his agency was barred by Section 6103 of the tax code from
communicating information to other federal agencies that would assist
those agencies in their law enforcement duties. He pointed out that the
IRS was barred from providing tax return information to the SEC,
federal bank regulators, and the Public Company Accounting Oversight
Board (PCAOB)--even, for example, when that information might assist
the SEC in evaluating whether an abusive tax shelter resulted in
deceptive accounting in a public company's financial statements, might
help the Federal Reserve determine whether a bank selling tax products
to its clients had violated the law against promoting abusive tax
shelters, or help the PCAOB judge whether an accounting firm had
impaired its independence by selling tax shelters to its audit clients.
A recent example demonstrates how harmful these information barriers
are to legitimate law enforcement efforts. In 2004, the IRS offered a
settlement initiative to companies and corporate executives who
participated in an abusive tax shelter involving the transfer of stock
options to family-controlled entities. Over a hundred corporations and
executives responded with admissions of wrongdoing. In addition to tax
violations, their misconduct may be linked to securities law violations
and improprieties by corporate auditors or banks, but the IRS has
informed the Subcommittee that it is currently barred by law from
sharing the names of the wrongdoers with the SEC, banking regulators,
or PCAOB.
These communication barriers are outdated, inefficient, and ill-
suited to stopping the torrent of tax shelter abuses now affecting or
being promoted by so many public companies, banks, and accounting
firms. To address this problem, Section 306 of this bill would
authorize the Treasury Secretary, with appropriate privacy safeguards,
to disclose to the SEC, federal banking agencies, and the PCAOB, upon
request, tax return information related to abusive tax shelters,
inappropriate tax avoidance, or tax evasion. The agencies could then
use this information only for law enforcement purposes, such as
preventing accounting firms or banks from promoting abusive tax
shelters, or detecting accounting fraud in the financial statements of
public companies.
The bill would also provide for increased disclosure of tax shelter
information to Congress. Section 307 would make it clear that companies
providing tax return preparation services to taxpayers cannot refuse to
comply with a Congressional document subpoena by citing Section 7216,
which prohibits tax return preparers from disclosing taxpayer
information to third parties. Several accounting and law firms raised
this claim in response to document subpoenas issued by the Permanent
Subcommittee on Investigations, contending they were barred by the
nondisclosure provision in Section 7216 from producing documents
related to the sale of abusive tax shelters to clients for a fee.
The accounting and law firms maintained this position despite an
analysis provided by the Senate legal counsel showing that the
nondisclosure provision was never intended to create a privilege or to
override a Senate subpoena, as demonstrated in federal regulations
interpreting the provision. This bill would codify the existing
regulations interpreting Section 7216 and make it clear that
Congressional document subpoenas must be honored.
Section 307 would also ensure Congress has access to information
about decisions by the Treasury related to an organization's tax exempt
status. A 2003 decision by the D.C. Circuit Court of Appeals, Tax
Analysts v. IRS, struck down certain IRS regulations and held that the
IRS must disclose letters denying or revoking an organization's tax
exempt status. The IRS has been reluctant to disclose such information,
not only to the public, but also to Congress, including in response to
requests by the Subcommittee.
For example, in 2005, the IRS revoked the tax exempt status of four
credit counseling firms, and, despite the Tax Analysts case, claimed
that it could not disclose to the Subcommittee the names of the four
firms or the reasons for revoking their tax exemption. Our bill would
make it clear that, upon receipt of a request from a Congressional
committee or subcommittee, the IRS must disclose documents, other than
a tax return, related to the agency's determination to grant, deny,
revoke or restore an organization's exemption from taxation.
The Treasury Department recently issued new standards for tax
practitioners issuing opinion letters on the tax implications of
potential tax shelters as part of Circular 230. Section 308 of the bill
would provide express statutory authority for these and even clearer
regulations.
The public has traditionally relied on tax opinion letters to obtain
informed and trustworthy advice about whether a tax-motivated
transaction meets the requirements of the law. The Permanent
Subcommittee on Investigations has found that, in too many cases, tax
opinion letters no longer contain disinterested and reliable tax
advice, even when issued by supposedly reputable accounting or law
firms. Instead, some tax opinion letters have become marketing tools
used by tax shelter promoters and their allies to sell clients on their
latest tax products. In many of these cases, financial interests and
biases were concealed, unreasonable factual assumptions were used to
justify dubious legal conclusions, and taxpayers were misled about the
risk that the proposed transaction would later be designated an illegal
tax shelter. Reforms are essential to address these abuses and restore
the integrity of tax opinion letters.
The Treasury Department recently adopted standards that address a
number of the abuses affecting tax shelter opinion letters; however,
the standards
[[Page S2216]]
could be stronger yet. Our bill would authorize Treasury to issue
standards addressing a wider spectrum of tax shelter opinion letter
problems, including: preventing concealed collaboration among
supposedly independent letter writers; avoiding conflicts of interest
that would impair auditor independence; ensuring appropriate fee
charges; preventing practitioners and firms from aiding and abetting
the understatement of tax liability by clients; and banning the
promotion of potentially abusive tax shelters. By addressing each of
these areas, a beefed-up Circular 230 could help reduce the ongoing
abusive practices related to tax shelter opinion letters.
Finally, Title IV of the bill incorporates a Baucus-Grassley proposal
which would strengthen legal prohibitions against abusive tax shelters
by codifying in Federal tax statutes for the first time what is known
as the economic substance doctrine. This anti-tax abuse doctrine was
fashioned by federal courts evaluating transactions that appeared to
have little or no business purpose or economic substance apart from tax
avoidance. It has become a powerful analytical tool used by courts to
invalidate abusive tax shelters. At the same time, because there is no
statute underlying this doctrine and the courts have developed and
applied it differently in different judicial districts, the existing
case law has many ambiguities and conflicting interpretations.
This language was developed under the leadership of Senators Baucus
and Grassley, the Chairman and Ranking Member of the Finance Committee.
The Senate has voted on multiple occasions to enact it into law, but
House conferees have rejected it each time. Since no tax shelter
legislation would be complete without addressing this issue, Title IV
of this comprehensive bill proposes once more to include the economic
substance doctrine in the tax code.
The eyes of some people may glaze over when tax shelters and tax
havens are discussed, but unscrupulous taxpayers and tax professionals
clearly see illicit dollar signs. Our commitment to crack down on their
tax abuses must be as strong as their determination to get away with
ripping off America and American taxpayers.
Our bill provides powerful new tools to end the tax haven and tax
shelter abuses. Tax haven and tax shelter abuses contribute nearly $100
billion to the $345 billion annual tax gap, which represents taxes owed
but not paid. It's long past time for taxes owing to the people's
Treasury to be collected. And it's long past time for Congress to end
the shifting of a disproportionate tax burden onto the shoulders of
honest Americans.
Mr. OBAMA. Mr. President, I rise today to speak about the Stop Tax
Haven Abuse Act, which I am proud to cosponsor with Senators Levin and
Coleman. This bill seeks to improve the fairness of our tax system by
deterring the abuse of secret tax havens and unacceptable tax avoidance
strategies. It is a serious solution to a serious problem.
An investigation by the Senate Permanent Subcommittee on
Investigations found that offshore tax havens and secrecy jurisdictions
hold trillions of dollars in assets and are often used as havens for
tax evasion, financial fraud, and money laundering. Experts estimate
that abusive tax shelters and tax havens cost this country between $40
billion and $70 billion every year, and the burden of filling this gap
is borne unfairly by taxpayers who follow the rules and can't afford
high-priced lawyers and accountants to help them game the system.
The problem is not new, but we need a new solution. Several years
ago, the subcommittee heard testimony from the owner of a Cayman Island
offshore bank who estimated that all of his clients--100 percent--were
engaged in tax evasion, and 95 percent were U.S. citizens. In 2000, the
Enron Corporation--remember Enron?--established over 441 offshore
entities in the Cayman Islands. A 2004 report found that U.S.
multinational corporations are increasingly attributing their profits
to offshore jurisdictions. A 2005 study of high-net-worth individuals
worldwide estimated that their offshore assets now total $11.5
trillion. The IRS has estimated that more than half a million U.S.
taxpayers have offshore bank accounts and access those funds with
offshore credit cards.
Unfortunately, the tax, corporate, or bank secrecy laws and practices
of about 50 countries make it nearly impossible for American
authorities to gain access to necessary information about U.S.
taxpayers in order to enforce U.S. tax laws. Today, the Government has
the burden of proving that a taxpayer has control of the tax haven
entity and is the beneficial owner. This allows taxpayers to rely on
the secrecy protections of tax havens to deceive Federal tax
authorities and evade taxes.
This is not a political issue of how low or high taxes ought to be.
This is a basic issue of fairness and integrity. Corporate and
individual taxpayers alike must have confidence that those who
disregard the law will be identified and adequately punished. Those who
defy the law or game the system must face consequences. Those who
enforce the law need the tools and resources to do so. We cannot sit
idly by while tax secrecy jurisdictions impede the enforcement of U.S.
law.
Under this bill, if you create a trust or corporation in a tax haven
jurisdiction, send it assets, or benefit from its actions, the Federal
Government will presume in civil judicial and administrative
proceedings that you control the entity and that any income generated
by it is your income for tax, securities, and money-laundering
purposes. The burden of proof shifts to the corporation or the
individual, who may rebut these presumptions by clear and convincing
evidence.
This bill provides an initial list of offshore secrecy jurisdictions
where these evidentiary presumptions will apply. Taxpayers with foreign
financial accounts in Anguilla, Bermuda, the Cayman Islands, or
Dominica, for example, should be prepared to report their accounts to
the IRS. And this bill will make it easier for the IRS to find such
taxpayers if they do not.
The Treasury Secretary may add to or subtract from the list of
offshore secrecy jurisdictions. The list does not reflect a
determination that a country is necessarily uncooperative but merely
that it is difficult to obtain adequate financial and beneficial
ownership information from that country and it is ripe for tax abuse.
If an offshore jurisdiction is in fact uncooperative and impedes U.S.
tax enforcement, however, this bill gives Treasury the authority to
impose sanctions, including the denial of the right to issue credit
cards for use in the United States.
This bill also establishes a $1 million penalty on public companies
or their officers who fail to disclose foreign holdings and requires
hedge funds and private equity funds to establish anti-money laundering
programs and to submit suspicious activity reports. Importantly, this
bill clarifies that the sole purpose of a transaction cannot
legitimately be to evade tax liability. Transactions must have
meaningful ``economic substance'' or a business purpose apart from tax
avoidance or evasion.
There is no such thing as a free lunch--someone always has to pay.
And when a crooked business or shameless individual does not pay its
fair share, the burden gets shifted to others, usually to ordinary
taxpayers and working Americans without access to sophisticated tax
preparers or corporate loopholes.
This bill strengthens our ability to stop shifting the tax burden to
working families. All of us must pay our fair share of the cost of
securing and running this country. There is no excuse for benefiting
from the laws and services, institutions, and economic structure of our
Nation, while evading your responsibility to do your part. I believe it
is our job to keep the system fair, and that is what this bill seeks to
do.
I commend Senator Levin and Senator Coleman for their leadership on
this important issue. I am proud to be a cosponsor of this bill and
urge my colleagues to support it.
______
By Mrs. FEINSTEIN:
S.J. Res. 3. A joint resolution to specify an expiration date for the
authorization of use of military force under the Authorization for Use
of Military Force Against Iraq Resolution of 2002 and to authorize the
continuing presence of United States forces in Iraq after that date for
certain military operations and activities; to the Committee on Foreign
Relations.
[[Page S2217]]
Mrs. FEINSTEIN. Yesterday, the House of Representatives clearly
expressed its support for our troops and its disapproval of the
President's action to escalate the war. Today, it is the Senate's turn.
Today, I believe that by voting for cloture, a majority of the Senate
will convey the same message. There may not be 60 votes, but I believe
there will be a majority. Our forces have been in Iraq for 4 years,
$380 billion has been spent, more than 3,000 troops have been killed,
and nearly 24,000 have been wounded. My home State of California has
lost more than 300 brave men and women, with thousands injured.
Iraq is in chaos: Sunni fighting Shia, Shia fighting Sunni, car
bombs, IEDs, assassinations, mortar attacks, downed helicopters, death
squads, and sabotaged infrastructure. Every day, we learn of new
attacks, new casualties, new bloodshed, and no end in sight.
I believe this surge is a mistake. Four years ago, U.S. Armed Forces
went to Iraq to be liberators. Today, they are caught in the bloody
crossfire of internecine fighting. The question is, Can the American
military solve a civil war? I don't believe it can. It was certainly
not the mission Congress authorized in 2002. So the time has come for
the Senate to say so, just as the House has done. The time has come to
declare that our time has come and gone in Iraq. The time has come to
speak clearly, and the time has come to change course.
The authorization for use of military force, approved by the Congress
in October 2002, carries with it congressional approval of this war.
The way to change course is to change that authorization. Therefore,
today, I introduce legislation that will put the expiration date of
December 31, 2007, on the authorization for use of military force.
The President would be required to return to Congress if he seeks to
renew the resolution. The resolution recognizes that conditions have
changed since the 2002 authorization was approved. Saddam Hussein is
gone. An Iraqi Government has been established. It also recognizes the
flaws of the 2002 authorization. Iraq, in fact, had no weapons of mass
destruction. It was not closely allied with al-Qaida.
This resolution does not call for a precipitous withdrawal--let me
stress that--but it sets a time limit--the remaining 10 months of the
year--to stage an orderly redeployment and to transition this mission.
That mission would be limited to training, equipping, and advising
Iraqi security and police forces; to force protection and security for
U.S. Armed Forces and civilian personnel; support of Iraqi security
forces for border security and protection, to be carried out with the
minimum forces required for that purpose; targeted counterterrorism
operations against al-Qaida and foreign fighters within Iraq; and
logistical support in connection with these activities.
I believe this legislation is the next logical step following today.
It is simple, it is concise. After the majority vote today sends our
disapproval to the President, it is time to consider the next step. I
submit this resolution as a possible next step.
I ask unanimous consent that the text of the joint resolution be
printed in the Record.
There being no objection, the joint resolution was ordered to be
printed in the Record, as follows:
S.J. Res. 3
Resolved by the Senate and House of Representatives of the
United States of America in Congress assembled,
SECTION 1. EXPIRATION OF AUTHORIZATION FOR USE OF MILITARY
FORCE AGAINST IRAQ.
The authority conveyed by the Authorization for Use of
Military Force Against Iraq Resolution of 2002 (Public Law
107-243) shall expire on December 31, 2007, unless otherwise
provided in a Joint Resolution (other than Public Law 107-
243) enacted by Congress.
SEC. 2. ALLOWANCE FOR CERTAIN MILITARY OPERATIONS AND
ACTIVITIES.
Section 1 shall not be construed as prohibiting or limiting
the presence of personnel or units of the Armed Forces of the
United States in Iraq after December 31, 2007, for the
following purposes:
(1) Training, equipping, and advising Iraqi security and
police forces.
(2) Force protection and security for United States Armed
Forces and civilian personnel.
(3) Support of Iraqi security forces for border security
and protection, to be carried out with the minimum forces
required for that purpose.
(4) Targeted counter-terrorism operations against al Qaeda
and foreign fighters within Iraq.
(5) Logistical support in connection with activities under
paragraphs (1) through (4).
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