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Before the Committee on Finance, U.S. Senate: 

United States Government Accountability Office: 

For Release on Delivery: 
Expected at 10:00 a.m. EDT:
Thursday, July 24, 2008: 

Cayman Islands: 

Business Advantages and Tax Minimization Attract U.S. Persons and 
Enforcement Challenges Exist: 

Statement of Michael Brostek: 
Director, Strategic Issues: 


GAO Highlights: 

Highlights of GAO-08-779T, a testimony to Chairman and Ranking Member, 
Committee on Finance, U.S. Senate. 

Why GAO Did This Study: 

The Cayman Islands is a major offshore financial center and the 
registered home of thousands of corporations and financial entities. 
Financial activity there is in the trillions of dollars annually. One 
Cayman building—Ugland House—has been the subject of public attention 
as the listed address of thousands of companies. 

To help Congress better understand the nature of U.S. persons’ business 
activities in the Cayman Islands, GAO was asked to study (1) the nature 
and extent of U.S. persons’ involvement with Ugland House registered 
entities and the nature of such business; (2) the reasons why U.S. 
persons conduct business in the Cayman Islands; (3) information 
available to the U.S. government regarding U.S. persons’ Cayman 
activities; and (4) the U.S. government’s compliance and enforcement 
efforts. GAO interviewed U.S. and Cayman government officials and 
representatives of the law firm housed in Ugland House, and reviewed 
relevant documents. The full report on GAO’s review is GAO-08-778, 
being released at the same time as this testimony. 

What GAO Found: 

The sole occupant of Ugland House is Maples and Calder, a law firm and 
company-services provider that serves as registered office for the 
18,857 entities it created as of March 2008, on behalf of a largely 
international clientele. According to Maples partners, about 5 percent 
of these entities were wholly U.S.-owned and 40 to 50 percent had a 
U.S. billing address. Ugland House registered entities are often 
participants in investment and structured-finance activities, including 
those related to hedge funds and securitization. 

Gaining business advantages, such as facilitating U.S.–foreign 
transactions or minimizing taxes, are key reasons for U.S. persons’ 
financial activity in the Cayman Islands. The Cayman Islands’ 
reputation as a stable, business-friendly regulatory environment also 
attracts business. This activity is typically legal, such as when 
pension funds and other U.S. tax-exempt entities invest in Cayman hedge 
funds to maximize their investment return by minimizing U.S. taxes. 
Nevertheless, as with other offshore jurisdictions, some U.S. persons 
may use Cayman Island entities to illegally evade income taxes or hide 
illegal activity. 

Information about U.S. persons’ Cayman activities comes from self-
reporting, international agreements, and less formal sharing with the 
Cayman government. Because there is often no third-party reporting, 
self-reported information may be vulnerable to being inaccurate or 
incomplete. U.S. officials said the Cayman government has been 
responsive to taxpayer-specific information requests. 

The Internal Revenue Service has several initiatives that target 
offshore tax evasion, including cases involving Cayman entities, but 
oversight and enforcement challenges related to offshore financial 
activity exist. U.S. officials said that cooperation with the Cayman 
Islands government has been good. Also, Maples partners said that 
ultimate responsibility for compliance with U.S. tax laws lies with 
U.S. taxpayers. 

Figure: Ugland House, George Town, Grand Cayman Island 

This figure contains a photograph of Ugland House, as well as the 
following supporting text: 

Ugland House: 
* Sole tenant is Maples and Calder law firm, which provides registered 
office services to companies established in the Cayman Islands; 
* 18,857 registered entities at the Ugland House address; 
- Very few have a significant physical presence in the Cayman Islands; 
- Five percent wholly U.S. owned; 
- Fewer than 50 percent have a U.S. billing address. 

Source: GAO photograph and statistics obtained from the Cayman Islands 
government and Maples. 

[End of figure] 

What GAO Recommends: 

GAO makes no recommendations in this testimony or the accompanying 
report. The Commissioner of Internal Revenue, the Secretary of the 
Treasury, and the Leader of Government Business of the Cayman Islands 
were provided a draft of the accompanying report and GAO incorporated 
their comments as appropriate. 

To view the full product, including the scope and methodology, click on 
[hyperlink,]. For more 
information, contact Michael Brostek at (202) 512-9110 or 

[End of section] 

Chairman Baucus, Senator Grassley, and Members of the Committee, 

I appreciate this opportunity to discuss offshore financial activity in 
the Cayman Islands and the challenges posed for both tax policy and 
administration. International financial activity is common in our 
increasingly global economy, and is encouraged or facilitated by 
various federal policies. Nevertheless, financial activity across 
foreign jurisdictions poses challenges for both tax policy and 

Recognizing the serious problems posed by offshore tax evasion, you 
asked us to study what is known about the business activities of U.S. 
taxpayers involving Ugland House in the Cayman Islands. Specifically, 
you asked us about the extent, motives, and tax implications of these 
activities, as well as the extent to which the U. S. government has 
looked into these taxpayer activities. The report we are issuing today 
[Footnote 1] focuses on these activities. The objectives of our report 
were to determine (1) the nature and extent of U.S. persons' 
involvement with Ugland House registered entities, and what business, 
if any, these entities carry on in Ugland House and in the Cayman 
Islands[Footnote 2]; (2) what reasons attract U.S. persons to conduct 
business in the Cayman Islands; (3) what information is available to 
the U.S. government regarding U.S. persons' Cayman Islands activities, 
including which are associated with U.S. taxpayers; and (4) for tax 
noncompliance and other related illegal activities, describe the U.S. 
government's compliance and enforcement efforts, and any related 
activity on the part of the Cayman Islands government. 

To address our objectives, we reviewed and analyzed U.S. government and 
private-sector documents; interviewed U.S. and Cayman Islands officials 
as well as partners of Maples and Calder, the law firm that occupies 
Ugland House; and examined data from sources in the U.S. and Cayman 
Islands related to Ugland House and the Cayman Islands. For more 
information on our methodology, please see the report we are issuing 
today in conjunction with this testimony. We conducted our work from 
July 2007 to July 2008 in accordance with generally accepted government 
auditing standards. Those standards require that we plan and perform 
the audit to obtain sufficient, appropriate evidence to provide a 
reasonable basis for our findings and conclusions based on our audit 
objectives. We believe that the evidence obtained provides a reasonable 
basis for our findings and conclusions based on our audit objectives. 


The Cayman Islands is a United Kingdom Overseas Territory located in 
the Caribbean Sea south of Cuba and northwest of Jamaica, with a total 
land area approximately 1.5 times the size of Washington, D.C., and a 
population of 47,862. While geographically small, the Cayman Islands is 
a major offshore financial center (OFC) with no direct taxes that 
attracts a high volume of U.S.-related financial activity, often 
involving institutions rather than individuals.[Footnote 3] Although 
not easily defined, OFCs are generally described as jurisdictions that 
have a high level of nonresident financial activity, and may have 
characteristics including low or no taxes, light and flexible 
regulation, and a high level of client confidentiality. The Cayman 
Islands reports that in 2008 it had 277 licensed banks, over 80,000 
registered companies, more than 9,000 registered investment funds, and 
760 captive insurance companies. According to the Department of the 
Treasury, U.S. investors held approximately $376 billion in Cayman- 
issued securities at the end of 2006, making it the fifth most common 
location for U.S. investment in foreign securities. As of September 
2007, U.S. banking liabilities to the Cayman Islands were the highest 
of any foreign jurisdiction, at nearly $1.5 trillion. As of June 2007, 
U.S. banking claims on the Cayman Islands stood at $940 billion, second 
only to the United Kingdom. 

U.S. Persons Are Frequently Associated With Ugland House Registered 

The international law firm of Maples and Calder, with its associated 
businesses - Maples Corporate Services Limited and Maples Finance 
Limited - is the sole occupant of Ugland House. Its business is to 
facilitate Cayman Islands-based international financial and commercial 
activity for a clientele of primarily international financial 
institutions, institutional investors, and corporations. Similar to 
corporate service providers in the United States, Maples Corporate 
Services Limited provides registered-office services, using Ugland 
House as a registered address, to entities it establishes. Registered- 
office services include activities such as maintenance of certain 
entity records and filing of statutory forms, resolutions, notices, 
returns, and fees. Cayman Islands law requires company-service 
providers like Maples and Calder to adhere to specific Anti-Money 
Laundering (AML) and Know-Your-Customer (KYC) requirements. For 
example, they must verify and keep records on the beneficial owners of 
entities to which they provide services, the purpose of the entities, 
and the sources of the funds involved. 

Very few Ugland House registered entities have a significant physical 
presence in the Cayman Islands or carry out business in the Cayman 
Islands. According to Maples and Calder partners, the persons 
establishing these entities are typically referred to Maples by counsel 
from outside the Cayman Islands, fund managers, and investment banks. 
As of March 2008 the Cayman Islands Registrar reported that 18,857 
entities were registered at the Ugland House address. Approximately 96 
percent of these entities were classified as exempted entities under 
Cayman Islands law, and were thus generally prohibited from carrying 
out domestic business within the Cayman Islands. 

Maples and Calder senior partners told us that approximately 5 percent 
of the entities registered at Ugland House were wholly owned by U.S. 
persons, while 40 to 50 percent were related to the U.S. in that they 
had a billing address in the United States. A U.S. billing address does 
not necessarily imply ownership or control. According to the partners, 
U.S. persons associated with Ugland House registered entities are often 
participants in investment and structured-finance activities, including 
those related to hedge funds and securitization. Entities associated 
with these activities are not generally directly owned or controlled. 
For instance, investment-fund entities are often established as 
partnerships and are essentially owned by the fund's investors. 
Structured-finance entities are not typically carried on a company's 
balance sheet, and ownership can be through a party other than the 
person directing the establishment of the entity, such as a charitable 
trust, or spread across many noteholders or investors, such as in deals 
involving securitization. The entities created by Maples and Calder 
that are directly owned or controlled include corporate subsidiaries, 
such as those used by multinational corporations to conduct 
international business. 

Several Factors Influence U.S. Taxpayers' Decisions to Conduct 
Financial Activity in the Cayman Islands: 

U.S. persons who conduct financial activity in the Cayman Islands 
commonly do so to gain business advantages, including tax advantages 
under U.S. law. Although such activity is typically legal, some persons 
have engaged in activity in the Cayman Islands, like other 
jurisdictions, in an attempt to avoid detection and prosecution of 
illegal activity by U.S. authorities. 

The Cayman Islands may attract U.S-related financial activity because 
of characteristics including its reputation for stability and 
compliance with international standards, its business-friendly 
regulatory environment, and its prominence as an international 
financial center. For instance, because the Cayman Islands' legal and 
regulatory system is generally regarded as stable and compliant with 
international standards, U.S. persons looking for a safe jurisdiction 
in which to place funds and assets may choose to carry out financial 
transactions there. Additionally, establishing a Cayman Islands entity 
can be relatively inexpensive--an exempted company can be created for 
less than $600, not taking into account service-provider fees. Further, 
U.S. persons may also be attracted to the Cayman Islands because it is 
proximate to the United States, operates in the same time zone as New 
York, and is English speaking. 

Another frequent reason for doing business in the Cayman Islands is to 
obtain tax advantages, such as through reduction or deferral of U.S. 
taxes. For instance, U.S. tax-exempt entities, such as university 
endowments and pension funds, may invest in hedge funds organized in 
the Cayman Islands in order to avoid the unrelated business income tax 
(UBIT). The investment income of U.S. tax-exempts may be subject to 
UBIT if earned by an investment vehicle organized as a U.S. 
partnership, a formation common among U.S.-based hedge funds. However, 
tax-exempts that invest in hedge funds organized as foreign 
corporations in jurisdictions like the Cayman Islands can be paid in 
dividends, which are not subject to UBIT. 

Additionally, some U.S. persons may use Cayman Islands entities to 
defer U.S. taxes. For example, a U.S.-based multinational business may 
create a Cayman Islands subsidiary to hold foreign earnings, which are 
not generally taxed in the United States unless or until repatriated. 
Because the Cayman Islands, like some other OFCs, has no direct taxes, 
Cayman subsidiaries do not incur additional taxes owed to the Cayman 
Islands government. One indication of the extent to which U.S. 
companies use Cayman entities to defer taxes is their reaction to a 
recent tax law. In 2004, Congress approved a received dividend 
reduction for certain earnings of foreign subsidiaries of U.S. 
companies repatriated for a limited time.[Footnote 4] Approximately 5.5 
percent of the nearly $362 billion repatriated between 2004 and 2006 
came from Cayman Island controlled foreign corporations. 

Lastly, as with other offshore jurisdictions, some U.S. persons may 
establish entities in the Cayman Islands to illegally evade taxes or 
avoid detection and prosecution of illegal activities. The full extent 
of illegal offshore financial activity is unknown, but risk factors 
include limited transparency related to foreign transactions,[Footnote 
5] and difficulties faced by U.S. regulators and the courts in 
successfully prosecuting foreign criminal activity. Voluntary 
compliance with U.S. tax obligations is substantially lower when income 
is not subject to withholding or third-party-reporting requirements. 
Because U.S.-related financial activity carried out in foreign 
jurisdictions is not subject to these requirements in many cases, 
persons who intend to evade U.S. taxes are better able to avoid 
detection. Persons intent on illegally evading U.S. taxes may be more 
likely to carry out financial activity in jurisdictions with no direct 
taxes, such as the Cayman Islands, because income associated with that 
activity will not be taxed within those jurisdictions. 

The U.S. Government Has Access To Several Information Sources Regarding 
U.S. Taxpayers' Business Activities in the Cayman Islands, but Most 
Information is Self Reported: 

Individual U.S. taxpayers and corporations are generally required to 
self-report their taxable income to the Internal Revenue Service (IRS). 
Similarly, publicly owned corporations traded on U.S. markets are 
required to file annual or quarterly statements with the Securities and 
Exchange Commission (SEC). When an individual or corporation conducts 
business in the Cayman Islands, there is often no third-party reporting 
of transactions, so disclosures to IRS and U.S. regulators are 
dependent on the accuracy and completeness of the self-disclosure. 
Cayman Islands financial institutions are often not required to file 
reports with IRS concerning U.S. taxpayers. This makes it more likely 
that there would be inaccurate reporting by U.S. taxpayers on their 
annual tax returns and SEC required filings. 

In addition to the information that both IRS and SEC receive from 
filers of annual or quarterly reports, the U.S. government also has 
formal information-sharing mechanisms by which it can receive 
information from foreign governments and financial institutions. In 
November of 2001, the United States signed a Tax Information Exchange 
Agreement (TIEA) with the government of the United Kingdom with regard 
to the Cayman Islands. The TIEA provides a process for IRS to request 
specific information related to taxpayers. IRS sends TIEA requests to 
the Cayman Islands based on requests from inside the agency. In 
addition to the TIEA, the U.S. government and the Cayman Islands also 
entered into a Mutual Legal Assistance Treaty (MLAT) in 1986. The MLAT 
enables activities such as extraditions, searches and seizures, 
transfer of accused persons, and general criminal information exchange, 
including in relation to specified tax matters. 

Since the TIEA began to go into effect, IRS has made a small number of 
requests for information to the Cayman Islands. An IRS official told us 
that those requests have been for either bank records of taxpayers or 
for ownership records of corporations. [Footnote 6] The IRS official 
also told us that the Cayman Islands government has provided the 
requested information in a timely manner for all TIEA requests. Since 
the MLAT went into effect and through the end of 2007, the Department 
of Justice told us that the U.S. government has made over 200 requests 
for information regarding criminal cases to the Cayman Islands. 

Some financial intelligence information on U.S. persons' Cayman 
activities is available to U.S. regulators. The U.S. government's 
financial intelligence unit, FinCEN,[Footnote 7] works to gather 
information about suspected financial crimes both offshore and 
domestic. As part of its research and analysis, FinCEN can make 
requests of its counterpart in the Cayman Islands, the Cayman Islands 
Financial Reporting Authority (CAYFIN). CAYFIN can and does make 
requests to FinCEN as well. FinCEN and CAYFIN routinely share 
suspicious activity information. 

In fiscal year 2007 CAYFIN made 25 suspicious activity information 
requests to FinCEN to follow up on potential new as well as existing 
Cayman Islands-generated suspicious activity reports (SARs), while 
FinCEN made 6 requests to CAYFIN. According to CAYFIN, financial 
institutions primarily filed suspicious activity reports on U.S. 
persons for suspicion of fraud related offenses. Other offenses leading 
to the filing of suspicious activity reports included drug trafficking, 
money laundering, and securities fraud, which mostly consisted of 
insider trading. 

In addition to the formal information sharing codified into law between 
the U.S. government and Cayman Islands government and financial 
institutions represented by TIEA and MLAT requests and SARs, Cayman 
Islands officials reported sharing with and receiving information from 
federal agencies, state regulators, and financial institutions. 

U.S. and Cayman Officials Have Taken Steps to Address Illegal Activity, 
but Enforcement Challenges Exist: 

To address the challenges posed by offshore illegal activity, IRS has 
targeted abusive transactions in areas related to transfer pricing, 
hedge funds, offshore credit cards, and promoters of offshore shelters. 
IRS officials said that some abusive transactions identified through 
these initiatives involved Cayman Islands entities, although the exact 
extent of this involvement was unclear because it does not maintain 
jurisdiction-specific statistics regarding abusive transactions. 

While the full extent of Cayman involvement in offshore illegal 
activity is unclear, U.S. officials were able to point to specific 
criminal investigations and prosecutions involving the Cayman Islands. 
Over the past five years IRS field agents have requested information 
regarding suspected criminal activity by U.S. persons in 45 instances 
pertaining to taxpayers or subjects in the Cayman Islands. We analyzed 
21 criminal and civil cases to identify common characteristics of legal 
violations related to the Cayman Islands. Among these cases, the large 
majority involved individuals, small businesses, and promoters, rather 
than large multinational corporations. While they were most frequently 
related to tax evasion, other cases involved securities fraud, money 
laundering, and various other types of fraud. In most instances, Cayman 
Islands bank accounts had been used, and several cases involved Cayman 
Islands companies or credit-card accounts. 

IRS and Department of Justice (DOJ) officials stated that particular 
aspects of offshore activity present challenges related to oversight 
and enforcement. Specifically, these challenges include lack of 
jurisdictional authority to pursue information, difficulty in 
identifying beneficial owners due to the complexity of offshore 
financial transactions and relationships among entities, and lengthy 
processes involved with completing offshore examinations. 

Despite these challenges, U.S. officials consistently report that 
cooperation by the Cayman Islands government in enforcement matters has 
been good. Further, both the International Monetary Fund (IMF) and the 
Caribbean Financial Action Taskforce (CFATF) have cited the Cayman 
Islands for its efforts to comply with international standards, such as 
those related to anti-money-laundering and terrorist-financing 
activities. However, Cayman Islands government officials and senior 
partners from Maples and Calder stated that their role in helping the 
U.S. ensure compliance with U.S. tax laws is necessarily limited. 
Cayman Islands government officials stated that they cannot administer 
other nations' tax laws and are not aware of any jurisdiction that 
undertakes such an obligation as a general matter. Senior partners from 
Maples and Calder stated that complying with U.S. tax obligations is 
the responsibility of the U.S. persons controlling the offshore 
entities, and that they require all U.S. clients to obtain onshore 
counsel regarding tax matters before they will act on their behalf. 
Cayman officials told us that until a request is made by the U.S. for 
tax-related assistance, the Cayman Islands government is "neutral" and 
does not act for or against U.S. tax interests. 

Concluding Observations: 

Ugland House provides an instructive case example of the tremendous 
challenges facing the U.S. tax system in an increasingly global 
economy. Although the Maples and Calder law firm provides services that 
even U.S. government-affiliated entities have found useful for 
international transactions and the Cayman Islands government has taken 
affirmative steps to meet international standards, the ability of U.S. 
persons to establish entities with relatively little expense in the 
Cayman Islands and similar jurisdictions facilitates both legal tax 
minimization and illegal tax evasion. Despite the Cayman Islands' 
adherence to international standards and the international commerce 
benefits gained through U.S. activities in the Cayman Islands, Cayman 
entities nevertheless can be used to obscure legal ownership of assets 
and associated income and to exploit grey areas of U.S. tax law to 
minimize U.S. tax obligations. Further, while the Cayman Islands 
government has cooperated in sharing information through established 
channels, as long as the U.S. government is chiefly reliant on 
information gained from specific inquiries and self-reporting, the 
Cayman Islands and other similar jurisdictions will remain attractive 
locations for persons intent on legally minimizing their U.S. taxes and 
illegally avoiding their obligations. 

Balancing the need to ensure compliance with our tax and other laws 
while not harming U.S. business interests and also respecting the 
sovereignty of the Cayman Islands and similar jurisdictions undoubtedly 
will be a continuing challenge for our nation. 

Chairman Baucus, Senator Grassley, and members of the committee, this 
concludes my testimony. I would be happy to answer any questions you 
may have at this time. 

Contact and Acknowledgments: 

For further information regarding this testimony, please contact 
Michael Brostek, Director, Strategic Issues, on (202) 512-9110 or Contact points for our offices of Congressional 
Relations and Public Affairs may be found on the last page of this 
statement. Individuals making key contributions to this testimony 
include David Lewis, Assistant Director; Perry Datwyler; S. Mike Davis; 
Robyn Howard; Brian James; Danielle Novak; Melanie Papasian; Ellen 
Phelps Ranen; Ellen Rominger; Jeffrey Schmerling; Shellee Soliday; 
Andrew Stephens; Jessica Thomsen; and Jonda VanPelt. 

This is a work of the U.S. government and is not subject to copyright 
protection in the United States. The published product may be 
reproduced and distributed in its entirety without further permission 
from GAO. However, because this work may contain copyrighted images or 
other material, permission from the copyright holder may be necessary 
if you wish to reproduce this material separately. 

[End of section] 


[1] See Cayman Islands: Business and Tax Advantages Attract U.S. 
Persons and Enforcement Challenges Exist, [hyperlink,] (Washington, D.C.: July, 

[2] Under the Internal Revenue Code, a United States person is (1) a 
citizen or resident of the United States, (2) a partnership created or 
organized in the United States or under the law of the United States or 
of any State, (3) a corporation created or organized in the United 
States or under the law of the United States or of any State, or (4) 
any estate or trust other than a foreign estate or foreign trust. 

[3] Direct taxes are taxes on income, and may take the form of taxes on 
personal and corporate income, social security contributions, and 
payroll taxes. 

[4] American Jobs Creation Act of 2004, Pub. L. No. 108-357, § 422, 118 
Stat. 1418, 1515-20 (Oct. 22, 2004). 

[5] Cayman Island government officials said that this is a common 
problem when one country seeks information on activities within another 

[6] The TIEA has been in effect for criminal cases since 2004 and for 
civil cases since 2006. 

[7] FinCEN, an intelligence and analysis organization, is part of the 
U.S. Department of the Treasury's Office of Terrorism and Financial 

[End of section] 

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