International Taxation
Large U.S. Corporations and Federal Contractors with Subsidiaries in Jurisdictions Listed as Tax Havens or Financial Privacy Jurisdictions Gao ID: GAO-09-157 December 18, 2008Many U.S. corporations operate globally and have foreign subsidiaries. The subsidiaries may be created, for example, to take advantage of sales opportunities or favorable labor conditions. In some cases they may be used to reduce taxes. GAO was asked to update its 2004 report on large federal contractors with subsidiaries in countries sometimes called tax havens because of low taxes and a general lack of transparency. In response, GAO determined how many of the 100 largest publicly traded U.S. corporations and the 100 largest publicly traded U.S. federal contractors have subsidiaries in jurisdictions listed as tax havens or financial privacy jurisdictions. GAO (1) combined three lists of such jurisdictions created by governmental, international, and academic sources and (2) identified large publicly traded U.S. corporations and federal contractors and the locations of their subsidiaries using the Fortune 500 list, a federal contracting Web site, and a Securities and Exchange Commission (SEC) database.
Eighty-three of the 100 largest publicly traded U.S. corporations in terms of 2007 revenue reported having subsidiaries in jurisdictions listed as tax havens or financial privacy jurisdictions. Sixty-three of the 100 largest publicly traded U.S. federal contractors in terms of fiscal year 2007 federal contract obligations reported having subsidiaries in such jurisdictions. Since subsidiaries may be established in listed jurisdictions for a variety of nontax business reasons, the existence of a subsidiary in a jurisdiction listed as a tax haven or financial privacy jurisdiction does not signify that a corporation or federal contractor established that subsidiary for the purpose of reducing its tax burden. GAO did not attempt to determine if corporations or contractors with subsidiaries in such jurisdictions engaged in transactions with their subsidiaries to reduce their tax burden. In addition, the SEC only requires public corporations to report significant subsidiaries, so the number of subsidiaries in jurisdictions listed as tax havens or financial privacy jurisdictions for each corporation or federal contractor may be understated in this report. There is no agreed-upon definition of a tax haven or agreed-upon list of jurisdictions that should be considered tax havens. However, various governmental, international, and academic sources used similar characteristics to define and identify tax havens. Some of the characteristics included no or nominal taxes; a lack of effective exchange of information with foreign tax authorities; and a lack of transparency in legislative, legal, or administrative provisions. A few sources used terms such as offshore financial centers or financial privacy jurisdictions to refer to jurisdictions with similar characteristics. Based on a review of a variety of sources, GAO identified three lists of tax havens or financial privacy jurisdictions. The three sources GAO used are (1) the Organization for Economic Co-operation and Development, (2) a National Bureau of Economic Research working paper, and (3) a U.S. District Court order granting leave for the Internal Revenue Service to serve a "John Doe" summons. GAO combined the three lists into one for the purposes of this report. GAO did not develop its own definition of tax haven or its own list of jurisdictions. In commenting on a draft of this report, the Department of the Treasury expressed concerns about GAO using a list of tax havens or financial privacy jurisdictions because there is no agreed-upon definition of tax havens or list of jurisdictions. However, GAO noted that there is no agreed-upon definition or list and also noted that the jurisdictions on the three lists used have similar characteristics. Further, background for one list said that industry analysts recognize them as offshore tax haven or financial privacy jurisdictions and that they are promoted as such
GAO-09-157, International Taxation: Large U.S. Corporations and Federal Contractors with Subsidiaries in Jurisdictions Listed as Tax Havens or Financial Privacy Jurisdictions
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Report to Congressional Requesters:
United States Government Accountability Office:
GAO:
December 2008:
International Taxation:
Large U.S. Corporations and Federal Contractors with Subsidiaries in
Jurisdictions Listed as Tax Havens or Financial Privacy Jurisdictions:
GAO-09-157:
GAO Highlights:
Highlights of GAO-09-157, a report to congressional requesters.
Why GAO Did This Study:
Many U.S. corporations operate globally and have foreign subsidiaries.
The subsidiaries may be created, for example, to take advantage of
sales opportunities or favorable labor conditions. In some cases they
may be used to reduce taxes. GAO was asked to update its 2004 report on
large federal contractors with subsidiaries in countries sometimes
called tax havens because of low taxes and a general lack of
transparency.
In response, GAO determined how many of the 100 largest publicly traded
U.S. corporations and the 100 largest publicly traded U.S. federal
contractors have subsidiaries in jurisdictions listed as tax havens or
financial privacy jurisdictions.
GAO (1) combined three lists of such jurisdictions created by
governmental, international, and academic sources and (2) identified
large publicly traded U.S. corporations and federal contractors and the
locations of their subsidiaries using the Fortune 500 list, a federal
contracting Web site, and a Securities and Exchange Commission (SEC)
database.
What GAO Found:
Eighty-three of the 100 largest publicly traded U.S. corporations in
terms of 2007 revenue reported having subsidiaries in jurisdictions
listed as tax havens or financial privacy jurisdictions. Sixty-three of
the 100 largest publicly traded U.S. federal contractors in terms of
fiscal year 2007 federal contract obligations reported having
subsidiaries in such jurisdictions. Since subsidiaries may be
established in listed jurisdictions for a variety of nontax business
reasons, the existence of a subsidiary in a jurisdiction listed as a
tax haven or financial privacy jurisdiction does not signify that a
corporation or federal contractor established that subsidiary for the
purpose of reducing its tax burden. GAO did not attempt to determine if
corporations or contractors with subsidiaries in such jurisdictions
engaged in transactions with their subsidiaries to reduce their tax
burden. In addition, the SEC only requires public corporations to
report significant subsidiaries, so the number of subsidiaries in
jurisdictions listed as tax havens or financial privacy jurisdictions
for each corporation or federal contractor may be understated in this
report.
There is no agreed-upon definition of a tax haven or agreed-upon list
of jurisdictions that should be considered tax havens. However, various
governmental, international, and academic sources used similar
characteristics to define and identify tax havens. Some of the
characteristics included no or nominal taxes; a lack of effective
exchange of information with foreign tax authorities; and a lack of
transparency in legislative, legal, or administrative provisions. A few
sources used terms such as offshore financial centers or financial
privacy jurisdictions to refer to jurisdictions with similar
characteristics. Based on a review of a variety of sources, GAO
identified three lists of tax havens or financial privacy
jurisdictions. The three sources GAO used are (1) the Organization for
Economic Co-operation and Development, (2) a National Bureau of
Economic Research working paper, and (3) a U.S. District Court order
granting leave for the Internal Revenue Service to serve a ’John Doe“
summons. GAO combined the three lists into one for the purposes of this
report. GAO did not develop its own definition of tax haven or its own
list of jurisdictions.
In commenting on a draft of this report, the Department of the Treasury
expressed concerns about GAO using a list of tax havens or financial
privacy jurisdictions because there is no agreed-upon definition of tax
havens or list of jurisdictions. However, GAO noted that there is no
agreed-upon definition or list and also noted that the jurisdictions on
the three lists used have similar characteristics. Further, background
for one list said that industry analysts recognize them as offshore tax
haven or financial privacy jurisdictions and that they are promoted as
such.
To view the full product, including the scope and methodology, click on
GAO-09-157. For more information, contact James R. White at (202) 512-
9110 or whitej@gao.gov.
[End of section]
Contents:
Letter:
Results:
Agency Comments and Our Evaluation:
Appendix I: Objectives, Scope, and Methodology:
Appendix II: The 100 Largest Publicly Traded U.S. Corporations:
Appendix III: The 100 Largest Publicly Traded U.S. Federal Contractors:
Appendix IV: Comments from the Department of the Treasury:
Appendix V: Comments from the Internal Revenue Service:
Appendix VI: GAO Contact and Staff Acknowledgments:
Table:
Table 1: Jurisdictions Listed as Tax Havens or Financial Privacy
Jurisdictions and the Sources of Those Jurisdictions:
Abbreviations:
[End of section]
EDGAR: Electronic Data Gathering, Analysis, and Retrieval database:
FPDS-NG: Federal Procurement Data System-Next Generation:
FSF: Financial Stability Forum:
IMF: International Monetary Fund:
IRS: Internal Revenue Service:
NBER: National Bureau of Economic Research:
OECD: Organization for Economic Co-operation and Development:
SEC: Securities and Exchange Commission:
TIEA: Tax Information Exchange Agreement:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
December 18, 2008:
The Honorable Carl Levin:
Chairman:
Permanent Subcommittee on Investigations:
Committee on Homeland Security and Governmental Affairs:
United States Senate:
The Honorable Byron L. Dorgan:
United States Senate:
Today, corporations operate in a global economy and most of the largest
U.S. corporations have subsidiaries in other countries. Corporations
have foreign subsidiaries for a variety of business reasons, including
reasons related to taxes. For example, a corporation may establish a
foreign subsidiary to take advantage of sales opportunities, natural
resources, or favorable labor conditions. In some cases, U.S. taxpayers
aggressively interpret U.S. tax law relating to foreign subsidiaries.
For example, the Department of the Treasury (Treasury) has found that
some U.S. corporations have aggressively set transfer prices[Footnote
1] to move income to offshore jurisdictions to avoid U.S. taxes.
[Footnote 2] Some offshore jurisdictions have no or nominal taxes and
are sometimes referred to as tax havens. In addition, we previously
reported that in 2004, for U.S. multinational corporations generally
the share of business activities related to income that are more likely
to be affected by income-shifting practices[Footnote 3] was
significantly larger in countries with relatively low effective tax
rates than the share of business activities that were least likely to
be affected by income-shifting practices (physical assets,
compensation, and employment).[Footnote 4]
Because of your interest in U.S. corporations that have subsidiaries in
tax havens and possible tax avoidance, you asked us to provide
information about those corporations as well as update similar
information about federal contractors that we reported in 2004.
[Footnote 5] In this report, as in our previous report, we did not
attempt to develop a list of tax havens. Instead, we reviewed various
governmental, international, and academic sources addressing offshore
business activity. We did not find an agreed-upon definition of a tax
haven or an agreed-upon list of the jurisdictions that should be
considered tax havens, but the sources we reviewed used similar
characteristics to define and identify tax havens.[Footnote 6] In
addition, a few sources used similar characteristics to describe
offshore financial centers or financial privacy jurisdictions.[Footnote
7] For the purposes of this report, we combined lists of jurisdictions
from three sources and, for brevity purposes, will refer to the
jurisdictions as jurisdictions listed as tax havens or financial
privacy jurisdictions. We did not develop our own definition of a tax
haven or our own list of jurisdictions. Our objectives in this report
were to:
* determine how many of the 100 largest publicly traded U.S.
corporations in terms of revenue have subsidiaries in jurisdictions
listed as tax havens or financial privacy jurisdictions and the amount
of federal contract obligations these corporation have, if any, and:
* determine how many of the 100 largest publicly traded U.S. federal
contractors in terms of contract obligations have subsidiaries in
jurisdictions listed as tax havens or financial privacy jurisdictions.
The three sources we used for jurisdictions listed as tax havens or
financial privacy jurisdictions are (1) the Organization for Economic
Co-operation and Development's (OECD) list of committed jurisdictions
and uncooperative tax havens,[Footnote 8] (2) a National Bureau of
Economic Research (NBER) working paper[Footnote 9] list of tax havens,
and (3) a U.S. District Court order[Footnote 10] granting leave for the
Internal Revenue Service (IRS) to serve a "John Doe" summons that
included a list of offshore tax haven or financial privacy
jurisdictions.[Footnote 11] We combined the jurisdictions on the OECD,
NBER, and John Doe summons lists because we did not have a basis for
excluding any of the identified jurisdictions, resulting in a list of
50 tax haven or financial privacy jurisdictions.
We used the 2008 Fortune 500 list,[Footnote 12] data from
USASpending.gov, the Federal Procurement Data System-Next Generation
(FPDS-NG),[Footnote 13] and contractor's Web sites to identify the 100
largest publicly traded U.S. corporations and U.S federal contractors
and the amount of federal contract obligations. We assessed the
reliability of USASpending.gov and FPDS-NG and determined that the data
were sufficiently reliable for determining the general extent of
federal contract obligations. We used the Securities and Exchange
Commission's (SEC) Electronic Data Gathering, Analysis, and Retrieval
database to determine where corporations reported having significant
subsidiaries. Our scope and methodology, including the basis for the
list of 50 jurisdictions listed as tax havens or financial privacy
jurisdictions, are described in greater detail in appendix I.
Results:
Eighty-three of the 100 largest publicly traded U.S. corporations in
terms of 2007 revenue reported having subsidiaries[Footnote 14] in
jurisdictions listed as tax havens or financial privacy jurisdictions
and 74 of the 83 had federal contracts in fiscal year 2007. For the 74
corporations, the amount of the federal contract obligations ranged
from $12,000 to over $23 billion. Additional details about these
corporations include the following:
* Eighty-six of the 100 corporations had foreign subsidiaries and 14
did not. Eighty-three of the 86 corporations had subsidiaries in
locations other than jurisdictions listed as tax havens or financial
privacy jurisdictions.
* Four of the 83 corporations that had subsidiaries in jurisdictions
listed as tax havens or financial privacy jurisdictions had more than
100 subsidiaries in such jurisdictions.
* For the 83 corporations with subsidiaries in jurisdictions listed as
tax havens or financial privacy jurisdictions, the number of such
subsidiaries ranged from 1 for nine corporations to a high of 427 for
one corporation.
* Twelve corporations had more than 50 percent of their foreign
subsidiaries in jurisdictions listed as tax havens or financial privacy
jurisdictions. Three of these 12 only had one foreign subsidiary.
* Corporations had subsidiaries in 36 of the 50 jurisdictions listed as
tax havens or financial privacy jurisdictions.
* Eight jurisdictions listed as tax havens or financial privacy
jurisdictions had more than 100 corporate subsidiaries, ranging from
123 to 569. For the jurisdiction with 569 subsidiaries, 372 were owned
by four corporations.
* Thirty-four of the 100 corporations are also on the list of 100
largest publicly traded U.S. federal contractors.
Sixty-three of the 100 largest publicly traded U.S. federal contractors
in terms of fiscal year 2007 contract obligations reported having
subsidiaries in jurisdictions listed as tax havens or financial privacy
jurisdictions, 34 did not, and 3 did not provide information about the
locations of all of their subsidiaries. The following additional
details about the federal contractors are based on the 97 contractors
that provided complete information.
* Seventy-two of the 97 federal contractors had foreign subsidiaries
and 25 did not. Sixty-nine of the 72 contractors also had subsidiaries
in locations other than jurisdictions listed as tax havens or financial
privacy jurisdictions.
* For the 63 federal contractors with subsidiaries in jurisdictions
listed as tax havens or financial privacy jurisdictions, the number of
such subsidiaries ranged from 1 for 11 contractors to a high of 83 for
1 contractor.
* Four federal contractors had more than 50 percent of their foreign
subsidiaries in jurisdictions listed as tax havens or financial privacy
jurisdictions. Three of the four had all of their foreign subsidiaries
in such jurisdictions.
* Federal contractors had subsidiaries in 34 of the 50 jurisdictions
listed as tax havens or financial privacy jurisdictions.
* Five of the jurisdictions listed as tax havens or financial privacy
jurisdictions had more than 100 federal contractor subsidiaries,
ranging from 111 to 156.
* Thirty-four of the 100 federal contractors are also on the list of
100 largest publicly traded U.S. corporations.
For a list of the 100 largest publicly traded U.S. corporations in
terms of 2007 revenues, the amount of their fiscal year 2007 federal
contract obligations, the number of foreign subsidiaries, the number of
foreign subsidiaries located in jurisdictions listed as tax havens or
financial privacy jurisdictions, and the locations of those
subsidiaries, see appendix II. For a list of the 100 largest publicly
traded U.S. federal contractors in terms of fiscal year 2007 contract
obligations, number of foreign subsidiaries, the number of foreign
subsidiaries located in jurisdictions listed as tax havens or financial
privacy jurisdictions, and the location of those subsidiaries, see
appendix III.
The existence of a subsidiary in a jurisdiction listed as a tax haven
or financial privacy jurisdiction does not signify that a corporation
or contractor established that subsidiary for the purpose of reducing
its tax burden. We did not attempt to determine if corporations or
contractors engaged in transactions with their subsidiaries in order to
reduce their tax burden.
Agency Comments and Our Evaluation:
Treasury's Deputy Assistant Secretary for International Tax Affairs
provided written comments on a draft of this report on December 9,
2008, and those comments are reprinted in appendix IV. He wrote that
Treasury takes offshore tax evasion very seriously and has taken strong
administrative and regulatory steps to address the problem. However,
the Deputy Assistant Secretary raised concerns about our use of a list
of tax havens and financial privacy jurisdictions because, as we noted
in the report, there is no agreed-upon definition of tax havens or list
of jurisdictions. He added that we did indeed produce such a list by
combining three lists prepared by others. He also stated that the lack
of consensus results from the fact that determining which jurisdictions
are tax havens may depend on whether the issue of interest concerns
individual or corporate taxpayers.
In order to respond to Congress's interest in learning about the extent
to which U.S. corporations and federal contractors have subsidiaries in
jurisdictions listed as tax havens or financial privacy jurisdictions,
we needed a list of such jurisdictions. We combined three lists of
jurisdictions listed as tax havens or financial privacy jurisdictions
prepared by others. We also stated in our report that we did not
develop our own definition of a tax haven or our own list of
jurisdictions. However, even though there is no agreed-upon definition,
we combined the three lists because the sources used similar
characteristics to define and identify tax havens or financial privacy
jurisdictions and there was substantial overlap between the countries
on the lists. Of the 50 jurisdictions included in this report, 24 are
on all three lists, 14 are on two of the lists, and 12 are on one list.
We did not exclude any of the identified jurisdictions because we did
not have a basis for doing so.
The Deputy Assistant Secretary specifically questioned our use of two
of the three lists--the OECD list and the list of jurisdictions
included in an IRS "John Doe" summons. The Deputy Assistant Secretary
said that the majority of countries have committed to meeting OECD
standards and many have signed tax information exchange agreements with
the United States. He found it surprising that we used the lack of an
updated list as the rationale for using what he characterized as the
2000 OECD list. We used an OECD list that was included in a May 3,
2007, written testimony by the Director, OECD Center for Tax Policy and
Administration, before the Senate Finance Committee, which referred to
the OECD 2000 list. We updated the May 2007 list based on information
on OECD's Web site. The Director of OECD's Centre for Tax Policy and
Administration acknowledged in a letter to GAO that OECD and others
have not provided a clear picture of which countries are making
progress toward meeting those commitments and which are not. Lacking an
unambiguous identification of the countries making or not making
progress, we included all of the countries on the updated OECD list
because we could not determine which countries are currently meeting
OECD standards.
Regarding our use of the jurisdictions identified in IRS's "John Doe"
summons, the Deputy Assistant Secretary noted that the list of
jurisdictions in the summons was put together for the specific purpose
of seeking information about individuals who had signature authority
over bank accounts or credit cards issued by financial institutions in
those jurisdictions and was not intended to suggest a general list of
jurisdictions that Treasury and IRS considered tax havens. He wrote
that it was unclear how the list of countries in the "John Doe" summons
was relevant to our report because the problems addressed in our report
and the summons are so different. We used the identified jurisdictions
because, as pointed out in appendix I, the declaration of an IRS agent
in support of the summons, which was granted by a U.S. District Court,
stated that the jurisdictions included in the summons "are all
recognized as principal offshore tax haven or financial privacy
jurisdictions by industry analysts and are actively marketed as such by
promoters of offshore schemes."
Finally, the Deputy Assistant Secretary expressed concern that the list
of jurisdictions in our report could be regarded as a blacklist and may
be used as the basis for the imposition of sanctions or other negative
measures. Our report provides information to Congress about the extent
to which U.S. corporations and federal contractors have subsidiaries in
jurisdictions listed as tax havens or financial privacy jurisdictions.
It does not make recommendations about changes to U.S. tax, economic,
or foreign policy. As noted in the report, corporations have
subsidiaries in such jurisdictions for a variety of business reasons,
including reasons related to taxes.
The Commissioner of Internal Revenue provided written comments on a
draft of this report in a December 11, 2008, letter which is reprinted
in appendix V. The Commissioner wrote that international tax issues are
some of the most complex that IRS confronts and that he has made these
a top priority in addition to IRS's continued efforts to combat
offshore tax evasion. In addition, he welcomed the support provided by
independent research and analysis that complements IRS's initiatives in
this area and expressed his appreciation of our work on this report and
this topic in general. The SEC provided oral comments of a technical
nature that were incorporated into our report.
As agreed with your offices, unless you publicly announce its contents
earlier, we plan no further distribution of this report until 30 days
after its date. At that time, we will send copies of this report to the
Secretary of the Treasury, the Commissioner of Internal Revenue, the
Chairman of the Securities and Exchange Commission, and other
interested parties. The report also will be available at no charge on
GAO's Web site at [hyperlink, http://www.gao.gov].
If any of your staff have any questions, please contact me at (202) 512-
9110 or whitej@gao.gov. Contact points for our Offices of Congressional
Relations and Public Affairs may be found on the last page of this
report. Key contributors to this report are listed in appendix VI.
Signed by:
James R. White:
Director, Tax Issues Strategic Issues Team:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
We had two objectives. Our first objective was to determine how many of
the 100 largest publicly traded U.S. corporations in terms of revenue
have subsidiaries in jurisdictions listed as tax havens or financial
privacy jurisdictions and the amount of federal contract obligations
these corporations have, if any. Our second objective was to determine
how many of the 100 largest publicly traded U.S. federal contractors in
terms of contract obligations have subsidiaries in jurisdictions listed
as tax havens or financial privacy jurisdictions. We did not determine
if corporations or contractors with subsidiaries in jurisdictions
listed as tax havens or financial privacy jurisdictions engaged in
transactions or took other actions with regard to their subsidiaries in
order to reduce their tax burden. Subsidiaries may be established in
listed jurisdictions for a variety of nontax business reasons. For both
objectives, we reviewed and analyzed relevant documents and interviewed
Department of the Treasury, Internal Revenue Service (IRS), and
Securities and Exchange Commission (SEC) officials.
Identifying Jurisdictions Listed as Tax Havens or Financial Privacy
Jurisdictions:
To address both objectives, we needed to identify jurisdictions that
have been listed as tax havens or financial privacy jurisdictions. For
this report as in our 2004 report on federal contractors with offshore
subsidiaries, we did not attempt to develop a list of such
jurisdictions.[Footnote 15] Instead, to find sources that may identify
such jurisdictions, we searched numerous governmental, international,
and academic Internet sites using various key words or phrases.
Examples of sites searched include those of the Department of the
Treasury, IRS, the Congressional Budget Office, the Congressional
Research Service, the Organization for Economic Co-operation and
Development (OECD),[Footnote 16] the International Monetary Fund (IMF),
the Financial Stability Forum (FSF),[Footnote 17] the World Bank,
EconLit, F&S Index (a global index of financial publications), Tax
Notes, and sites that include excerpts from legislative documents, such
as bills or committee reports. Examples of key words or phrases
searched include tax havens, offshore tax havens, secrecy
jurisdictions, offshore secrecy jurisdictions, and offshore financial
centers. Our review of these sites did not find an agreed-upon
definition for a tax haven or an agreed-upon list of jurisdictions that
should be considered tax havens. However, the sources we reviewed used
similar characteristics to define and identify tax havens, including no
or nominal taxes; lack of effective exchange of tax information with
foreign tax authorities; lack of transparency in the operation of
legislative, legal, or administrative provisions; no requirement for a
substantive local presence; and self-promotion as an offshore financial
center. In addition, a few sources used characteristics similar to
those used in describing tax havens to describe offshore financial
centers[Footnote 18] or financial privacy jurisdictions.[Footnote 19]
For brevity purposes, we referred to the jurisdictions included in our
report as jurisdictions listed as tax havens or financial privacy
jurisdictions.
Based on our research, we identified the following three lists of
jurisdictions considered to be tax havens or financial privacy
jurisdictions.[Footnote 20]
* OECD's list of committed jurisdictions and uncooperative tax havens.
[Footnote 21]
* A National Bureau of Economic Research (NBER) working paper,[Footnote
22] which included a list of tax havens that was based on research
summarized in an article in The Quarterly Journal of Economics.
[Footnote 23]
* A U.S. District Court order granting leave for IRS to serve a "John
Doe" summons,[Footnote 24] which included a list of jurisdictions that
are recognized as offshore tax haven or financial privacy
jurisdictions[Footnote 25] by industry analysts and are actively
promoted as such by promoters of offshore schemes.[Footnote 26]
We combined the jurisdictions on the three lists because we did not
have a basis for excluding any of the identified jurisdictions. This
resulted in a list of 50 jurisdictions listed as tax havens or
financial privacy jurisdictions. The 50 jurisdictions as well as the
sources for the jurisdictions are shown in table 1. Of the 50
jurisdictions, 24 are on all three lists, 14 are on two of the lists,
and 12 are on one list.
Table 1: Jurisdictions Listed as Tax Havens or Financial Privacy
Jurisdictions and the Sources of Those Jurisdictions:
Jurisdiction: Andorra;
OECD: [Check][A];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Empty].
Jurisdiction: Anguilla;
OECD: [Check];
NBER: [Check]; U.S.
District Court order granting leave for IRS to serve a "John Doe"
summons: [Check].
Jurisdiction: Antigua and Barbuda;
OECD: [Check];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check][B].
Jurisdiction: Aruba;
OECD: [Check];
NBER: [Empty];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check][B].
Jurisdiction: Bahamas;
OECD: [Check];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check][B].
Jurisdiction: Bahrain;
OECD: [Check];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Empty].
Jurisdiction: Barbados;
OECD: [Empty];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check][B].
Jurisdiction: Belize;
OECD: [Check];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check].
Jurisdiction: Bermuda;
OECD: [Check];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check][B, C].
Jurisdiction: British Virgin Islands;
OECD: [Check];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check][D].
Jurisdiction: Cayman Islands;
OECD: [Check];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check][B].
Jurisdiction: Cook Islands;
OECD: [Check];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check].
Jurisdiction: Costa Rica;
OECD: [Empty];
NBER: [Empty];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check][B].
Jurisdiction: Cyprus;
OECD: [Check];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check][C].
Jurisdiction: Dominica;
OECD: [Check];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check][B].
Jurisdiction: Gibraltar;
OECD: [Check];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check].
Jurisdiction: Grenada;
OECD: [Check];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check][B].
Jurisdiction: Guernsey;
OECD: [Check];
NBER: [Check][D];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check][B, E].
Jurisdiction: Hong Kong;
OECD: [Empty];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check].
Jurisdiction: Ireland;
OECD: [Empty];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Empty].
Jurisdiction: Isle of Man;
OECD: [Check];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check][B].
Jurisdiction: Jersey;
OECD: [Check];
NBER: [Check][D];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check][B].
Jurisdiction: Jordan;
OECD: [Empty];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Empty].
Jurisdiction: Latvia;
OECD: [Empty];
NBER: [Empty];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check][C].
Jurisdiction: Lebanon;
OECD: [Empty];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Empty].
Jurisdiction: Liberia;
OECD: [Check];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Empty].
Jurisdiction: Liechtenstein;
OECD: [Check][A];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check].
Jurisdiction: Luxembourg;
OECD: [Empty];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: X[C].
Jurisdiction: Macao;
OECD: [Empty];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Empty].
Jurisdiction: Maldives;
OECD: [Empty];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Empty].
Jurisdiction: Malta;
OECD: [Check];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check].
Jurisdiction: Marshall Islands;
OECD: [Check];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Empty].
Jurisdiction: Mauritius;
OECD: [Check];
NBER: [Empty];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Empty].
Jurisdiction: Monaco;
OECD: [Check][A];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Empty].
Jurisdiction: Montserrat;
OECD: [Check];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Empty].
Jurisdiction: Nauru;
OECD: [Check];
NBER: [Empty];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check].
Jurisdiction: Netherlands Antilles;
OECD: [Check];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check][B].
Jurisdiction: Niue;
OECD: [Check];
NBER: [Empty];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Empty].
Jurisdiction: Panama;
OECD: [Check];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check].
Jurisdiction: Samoa;
OECD: [Check];
NBER: [Empty];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check].
Jurisdiction: San Marino;
OECD: [Check];
NBER: [Empty];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Empty].
Jurisdiction: Seychelles;
OECD: [Check];
NBER: [Empty];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Empty].
Jurisdiction: Singapore;
OECD: [Empty];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check].
Jurisdiction: St. Kitts and Nevis;
OECD: [Check];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check].
Jurisdiction: St. Lucia;
OECD: [Check];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: v[F].
Jurisdiction: St. Vincent and the Grenadines;
OECD: [Check];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check].
Jurisdiction: Switzerland;
OECD: [Empty];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: X[C].
Jurisdiction: Turks and Caicos Islands;
OECD: [Check];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check].
Jurisdiction: U.S. Virgin Islands;
OECD: v;
NBER: [Empty];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Empty].
Jurisdiction: Vanuatu;
OECD: [Check];
NBER: [Check];
U.S. District Court order granting leave for IRS to serve a "John Doe"
summons: [Check].
Sources: OECD, NBER, and John Doe summons.
[A] These are uncooperative tax havens; the remaining are committed
jurisdictions. These terms are explained in the following paragraph.
[B] A Tax Information Exchange Agreement (TIEA) is in force between the
United States and this jurisdiction.
[C] A double tax treaty is in force with an exchange of information
provision. For Switzerland, the treaty provides that the competent
authorities of the contracting states shall exchange such information
as is necessary "for the prevention of tax fraud or the like."
[D] NBER's list included the Channel Islands. Jersey and Guernsey are
part of the Channel Islands. The two other sources we used to identify
tax havens listed Jersey and Guernsey as two separate tax havens and
did not include the Channel Islands on their lists of tax havens. To be
consistent, we are including Jersey and Guernsey as tax havens on the
bureau's list rather than the Channel Islands.
[E] The John Doe summons lists Guernsey/Sark/Alderney. OECD only
included Guernsey. Since Sark and Alderney are part of the Bailiwick of
Guernsey, to be consistent, we are only including Guernsey on our list
of tax havens.
[F] The TIEA signed by the United States and St. Lucia on January 30,
1987, is not in effect within the meaning of section 274(h)(6)(A)(i) of
the Internal Revenue Code because the government of St. Lucia has not
enacted legislation to implement the agreement.
[End of table]
Organization for Economic Co-operation and Development:
As of February 2008, OECD lists 38 jurisdictions--35 that have made
commitments to cooperate with OECD in addressing issues related to
transparency and the effective exchange of information and 3 that have
not made such commitments.[Footnote 27] OECD refers to the 35 as
committed jurisdictions and the remaining 3 as uncooperative tax
havens. Although OECD does not provide a unique definition of the term
tax haven, OECD has established a set of criteria to characterize a tax
haven. Specifically, OECD stipulates four major features of a tax
haven: (1) no or nominal income tax; (2) rules that prevent the
effective exchange of information with foreign tax authorities; (3) a
lack of transparency in the operation of legislative, legal, or
administrative provisions; and (4) the absence of a requirement for a
substantive local presence. In general, OECD classifies a country as a
tax haven if it meets the criterion of no or nominal income tax, and at
least one of the other criteria. Most of the committed jurisdictions
agreed to cooperate with OECD in addressing "harmful tax practices" by
December 31, 2005. However, OECD reported in October 2007 that some
jurisdictions that committed to implementing standards on transparency
and the effective exchange of information had failed to do so, although
OECD did not specify which or how many jurisdictions had not made
progress. As a result, we included all 38 jurisdictions in our review.
National Bureau of Economic Research:
An NBER December 2006 working paper[Footnote 28] that attempts to
determine which jurisdictions become tax havens uses as its basic
definition the list of 41 countries and territories identified as tax
havens by Hines and Rice in a 1994 article in The Quarterly Journal of
Economics.[Footnote 29] This list is based on the coexistence of low
business tax rates in a jurisdiction in 1982 and its identification as
a tax haven by multiple authoritative sources. As explained below, this
resulted in a list of 40 tax havens that we used in our review.
Although The Quarterly Journal of Economics article identifies 41
countries as tax havens, the NBER study revised this list to include 39
countries. First, The Quarterly Journal of Economics article included
the United Kingdom Caribbean Islands and St. Martin. The NBER study
deleted the United Kingdom Caribbean Islands from the list because the
United Kingdom Caribbean Islands is a general term used by the Bureau
of Economic Analysis for British dependencies in the Caribbean, and
most of these dependencies are included as separate tax havens on the
list (Anguilla, Montserrat, the Cayman Islands, and the Turks and
Caicos Islands). Second, the NBER study also deleted St. Martin from
the list because it is part of the Netherlands Antilles and the
Netherlands Antilles is already included on the list.
The NBER study and The Quarterly Journal of Economics article included
the Channel Islands on the list of tax havens. Jersey and Guernsey are
part of the Channel Islands. The other sources we used to identify tax
havens listed Jersey and Guernsey as two separate tax havens and did
not include the Channel Islands on their lists of tax havens or
financial privacy jurisdictions. To be consistent, we are including
Jersey and Guernsey as tax havens rather than the Channel Islands. When
this criterion is applied, the NBER study includes 40 tax
havens.[Footnote 30]
Per The Quarterly Journal of Economics article, tax havens are often
defined as locations with the following four attributes: (1) low
corporate or personal tax rates, (2) legislation that supports banking
and business secrecy, (3) advanced communication facilities, and (4)
self-promotion as an offshore financial center. The Quarterly Journal
of Economics list of tax havens is a combination of the following:
* The authors started with a list of 32 tax haven countries that
Glautier and Bassinger reported in 1987 were in the Internal Revenue
Manual. They deleted 3 countries in which the foreign corporate tax
paid by U.S. companies was greater than 20 percent of pretax income
resulting in a list of 29 tax haven countries.
* Next, the authors used Andre Beauchamp's[Footnote 31] list of tax
haven countries. This list included all of the IRS-identified countries
plus 15 others. The authors added the Beauchamp countries, which had an
average tax rate lower than 10 percent for U.S. companies. This
resulted in adding 7 countries to the list.
* They applied the same criteria (average tax rate lower than 10
percent for U.S. companies) to the countries discussed in the Economist
Intelligence Unit's[Footnote 32] tax haven volume developed by Caroline
Doggart[Footnote 33] in 1983 that they applied to the countries
included in the Beauchamp study. This resulted in adding five countries
to the list.
This resulted in a list of 41 tax havens. As previously explained, to
be consistent with other sources we used to identify tax havens, there
are 40 tax havens on this list.
John Doe Summons:
On October 14, 2005, the United States filed in the U.S. District Court
for the Northern District of California an ex parte petition for leave
to serve a "John Doe" summons upon PayPal, Inc. and its affiliates and
subsidiaries pursuant to sections 7402(a), 7609(f), and 7609(h) of the
Internal Revenue Code,[Footnote 34] and the court issued an order
granting leave to serve the John Doe summons in February 2006.[Footnote
35]A John Doe summons is a third-party summons[Footnote 36] that does
not identify the person with respect to whose tax liability the summons
is issued and may be served only after a court proceeding.[Footnote 37]
The summons was for information on U.S. taxpayers who, during the years
ended December 31, 1999, through December 31, 2004, had signature
authority over bank accounts at or over MasterCard, VISA, or American
Express cards issued by, through, or on behalf of banks or other
financial institutions in 34 jurisdictions.
Supporting the petition was a declaration of an IRS revenue agent.
[Footnote 38] The IRS agent stated that IRS was conducting an
investigation to determine the correct federal income tax liabilities,
for the years ended December 31, 1999, through December 31, 2004, of
U.S. taxpayers who had signature authority over bank accounts or other
MasterCard, VISA, or American Express cards issued by, through, or on
behalf of banks or other financial institutions in the same 34
jurisdictions. Further, in the declaration the agent states the
following:
"Based upon my experience and information received from other
investigations, it is likely that a number of the persons who have
signature authority over bank accounts at or over American Express,
MasterCard, or VISA payment cards issued by, through, or for banks or
other financial institutions in the jurisdictions identified — may have
been under-reporting income, evading income taxes, or otherwise
violating the internal revenue laws of the United States."[Footnote 39]
In this declaration, the IRS revenue agent stated that the 34
jurisdictions listed on the John Doe summons to PayPal "are widely
known as places where, because of strict bank secrecy laws and devices
such as International Business Corporations, trusts and other
subterfuges, persons can shield their wealth from taxation in their
home countries. These jurisdictions are all recognized as principal
offshore tax haven or financial privacy jurisdictions by industry
analysts and are actively marketed as such by promoters of offshore
schemes."[Footnote 40] The declaration explains that these
jurisdictions were selected "on the reasonable belief that United
States taxpayers have failed or may have failed to comply with
provisions of the internal revenue laws through the use of American
Express, MasterCard, or VISA payment cards issued by, through, or on
behalf of banks and other financial institutions in those
jurisdictions."[Footnote 41]
Identifying the Largest Corporations and Federal Contractors and Their
Subsidiaries in Jurisdictions Listed as Tax Havens or Financial Privacy
Jurisdictions:
For the first objective, we used the Fortune 500 list to identify the
100 largest publicly traded U.S. corporations in terms of revenue for
2007.[Footnote 42] We used data from USASpending.gov[Footnote 43] to
determine if these corporations had 2007 fiscal year federal contract
obligations and, if so, the amount of those obligations. For the second
objective, we used USASpending.gov to identify the largest federal
contractors based on fiscal year 2007 obligations and used information
from the contractors' Web sites and the Fortune 500 list to determine
if they were publicly traded U.S. corporations. Based on this
information, we developed a list of the 100 largest publicly traded
U.S. federal contractors.
USASpending.gov utilizes data from the Federal Procurement Data System-
Next Generation (FPDS-NG) and aggregates subsidiaries and divisions by
parent company using information provided by Dun and Bradstreet. To
assess the reliability of USASpending.gov and FPDS-NG data, we reviewed
documentation about the data and systems that produced them, including
the FPDS-NG data element dictionary, data validation rules, and
certification process. Based on this, we determined that the data were
sufficiently reliable for the purpose of determining the general extent
of federal contract obligations. However, because of situations in
which corporations may participate in other activities, such as joint
ventures; limited information on some corporations; and the constantly
changing circumstances of corporations, their holdings, and their
contracts, we faced challenges in developing a list of the largest
federal contractors and determining the total obligations of those
contracts. As a result, we developed the following criteria to develop
the list of the 100 largest publicly traded U.S. federal contractors
and to determine the amounts of contract obligations:
* First, we excluded subsidiaries and joint ventures because they are
not publicly traded.[Footnote 44]
* Second, if we could not determine if a contractor was a publicly
traded U.S. corporation, we did not include the contractor on our list.
In these cases we often identified news articles or information from
the contractor's Web sites that indicated that the contractor was not
publicly traded or was not a U.S. company, such as only finding
information about the contractor in a foreign language.
* Third, in determining the amount of obligations, if a subsidiary of a
contractor was listed, we did not add the dollar amount of the
subsidiary's contract to the parent's contract, and if a contractor was
listed twice, we used the dollar amount only from the first listing of
the contractor and did not add the contract amount(s) from any other
listings for that contractor. We did not add subsidiary contracts to
parents' contracts or add multiple listings of the same contractor
because if we did so, then to ensure that we used comparable data for
other contractors, we would have needed to review the entire list of
federal contractors and conduct additional research for each contractor
to identify other subsidiaries or multiple listings. Since the federal
contract amount is secondary to the main purpose of our review--to
identify the extent of subsidiaries in jurisdictions that may be listed
as tax havens or financial privacy jurisdictions--we determined that
not reviewing the entire list of federal contractors was an acceptable
limitation for our review.
Using these criteria likely resulted in lower estimates of contract
obligations for some federal contractors as well as the contract
obligations for some of the largest corporations.
To address both objectives, we used Form 10-K[Footnote 45] and Exhibit
21,[Footnote 46] which are included in the SEC's Electronic Data
Gathering, Analysis, and Retrieval database (EDGAR), to determine the
locations of corporations' and contractors' subsidiaries based on their
latest filings with the SEC at the time of our review. Since the
principal executive officer(s), the principal financial officer(s), the
controller or principal accounting officer, and at least the majority
of the board of directors or persons with similar functions must sign
the form filed with the SEC that includes the subsidiaries, we did not
take additional steps to verify the accuracy of information found in
EDGAR. Also, since the SEC only requires public corporations to report
their significant subsidiaries, we were only able to identify the
subset of corporate subsidiaries meeting the definition of significant
subsidiary. Within Exhibit 21, public corporations may omit information
on those subsidiaries that do not constitute significant subsidiaries
when considered in the aggregate. The SEC considers a subsidiary to be
significant if (1) the parent corporation's and its other subsidiaries'
investments in and advances to the subsidiary exceed 10 percent of the
consolidated total assets of the parent corporation and its
subsidiaries, (2) the parent corporation's and its other subsidiaries'
proportionate share of the total assets (after intercompany
eliminations) of the subsidiary exceeds 10 percent of the consolidated
total assets of the parent corporation and its subsidiaries, or (3) the
parent corporation and its other subsidiaries' equity in the income
from continuing operations[Footnote 47] exceeds 10 percent of the
consolidated income from continuing operations of the parent
corporation and its subsidiaries. Corporations may also omit
information on consolidated wholly owned multiple subsidiaries carrying
on the same line of business (such as chain stores). Since the SEC only
requires public corporations to report significant subsidiaries, the
number of subsidiaries in jurisdictions listed as tax havens or
financial privacy jurisdictions for each corporation or federal
contractor may be understated in this report.
[End of section]
Appendix II: The 100 Largest Publicly Traded U.S. Corporations:
Corporation: 3M;
Rank by revenue: 94;
2007 Revenue (dollars in millions): $24,462;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $31,275;
Number of foreign subsidiaries: 62;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 9;
Bermuda (1);
Hong Kong (1);
Luxembourg (2);
Singapore (3);
Switzerland (2).
Corporation: Abbott Laboratories;
Rank by revenue: 91;
2007 Revenue (dollars in millions): $25,914;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $66,126;
Number of foreign subsidiaries: 168;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 36;
Bahamas (2);
Barbados (1);
Bermuda (5);
Costa Rica (1);
Grenada (1);
Hong Kong (1);
Ireland (13);
Latvia (1);
Lebanon (1);
Panama (2);
Singapore (2);
Switzerland (5);
Virgin Islands (1)[B].
Corporation: Aetna;
Rank by revenue: 83;
2007 Revenue (dollars in millions): $27,600;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $192;
Number of foreign subsidiaries: 14;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 8;
Bermuda (4);
Cayman Islands (1);
Hong Kong (2);
Ireland (1).
Corporation: Alcoa;
Rank by revenue: 79;
2007 Revenue (dollars in millions): $30,748;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $80,235;
Number of foreign subsidiaries: 31;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 4;
Hong Kong (1);
Luxembourg (2);
Switzerland (1).
Corporation: Allstate;
Rank by revenue: 63; 2007
Revenue (dollars in millions): $36,769;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: 0;
Number of foreign subsidiaries: 7;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 1;
Bermuda (1).
Corporation: Altria Group;
Rank by revenue: 60;
2007 Revenue (dollars in millions): $38,051;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: 0;
Number of foreign subsidiaries: 163;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 38;
British Virgin Islands (3);
Cayman Islands (1);
Costa Rica (2);
Hong Kong (1);
Ireland (2);
Latvia (1);
Luxembourg (1);
Netherlands Antilles (1);
Panama (2);
Singapore (3);
Switzerland (21).
Corporation: American Express;
Rank by revenue: 74;
2007 Revenue (dollars in millions): $32,316;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $355;
Number of foreign subsidiaries: 165;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 39;
Bahrain (2);
British Virgin Islands (2);
Cayman Islands (9);
Guernsey (6);
Hong Kong (4);
Jersey (4);
Luxembourg (3);
Netherlands Antilles (2);
Panama (1);
Singapore (2);
Switzerland (4).
Corporation: American International Group;
Rank by revenue: 13;
2007 Revenue (dollars in millions): $110,064;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $598;
Number of foreign subsidiaries: 88;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 18;
Bahrain (2);
Bermuda (5);
Hong Kong (3);
Ireland (3);
Luxembourg (1);
Panama (1);
Switzerland (3).
Corporation: AmerisourceBergen Corporation;
Rank by revenue: 28;
2007 Revenue (dollars in millions): $66,074;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $1,469,378;
Number of foreign subsidiaries: 0;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Corporation: Apple;
Rank by revenue: 97;
2007 Revenue (dollars in millions): $24,006;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $2,221;
Number of foreign subsidiaries: 1;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 1;
Ireland (1).
Corporation: Archer-Daniels-Midland Company;
Rank by revenue: 51;
2007 Revenue (dollars in millions): $44,018;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $197,488;
Number of foreign subsidiaries: 6;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 3;
Cayman Islands (2);
Ireland (1).
Corporation: AT&T, Inc.;
Rank by revenue: 10;
2007 Revenue (dollars in millions): $118,928;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $519,233;
Number of foreign subsidiaries: 0;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Corporation: Bank of America Corporation;
Rank by revenue: 9;
2007 Revenue (dollars in millions): $119,190;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $13,763;
Number of foreign subsidiaries: 311;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 115;
Bahamas (3);
Bermuda (2);
Cayman Islands (59);
Gibraltar (2);
Hong Kong (8);
Ireland (14);
Jersey (3);
Luxembourg (15);
Mauritius (3);
Singapore (5);
U.S. Virgin Islands (1).
Corporation: Berkshire Hathaway, Inc.;
Rank by revenue: 11;
2007 Revenue (dollars in millions): $118,245;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $235,394;
Number of foreign subsidiaries: 27;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 1;
Ireland (1).
Corporation: Best Buy;
Rank by revenue: 65;
2007 Revenue (dollars in millions): $35,934;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $1,885;
Number of foreign subsidiaries: 35;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 13;
Bermuda (2);
Hong Kong (2);
Luxembourg (1);
Mauritius (7);
Turks and Caicos Islands (1).
Corporation: The Boeing Company;
Rank by revenue: 27;
2007 Revenue (dollars in millions): $66,387;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $23,312,965;
Number of foreign subsidiaries: 135;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 38;
Bermuda (6);
Cayman Islands (1);
Gibraltar (2);
Hong Kong (4);
Ireland (4);
Netherlands Antilles (2);
Singapore (3);
U.S. Virgin Islands (16).
Corporation: Cardinal Health, Inc.;
Rank by revenue: 19;
2007 Revenue (dollars in millions): $88,364;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $1,039,243;
Number of foreign subsidiaries: 135;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 23;
Barbados (1);
Bermuda (2);
British Virgin Islands (1);
Cayman Islands (1);
Hong Kong (1);
Ireland (5);
Luxembourg (3);
Malta (1);
Mauritius (1);
Singapore (3);
Switzerland (4).
Corporation: Caterpillar, Inc.;
Rank by revenue: 49;
2007 Revenue (dollars in millions): $44,958;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $171,485;
Number of foreign subsidiaries: 329;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 49;
Barbados (1);
Bermuda (13);
Costa Rica (1);
Guernsey (1);
Hong Kong (3);
Ireland (2);
Luxembourg (3);
Mauritius (1);
Panama (3);
Singapore (8);
Switzerland (13).
Corporation: Chevron;
Rank by revenue: 3;
2007 Revenue (dollars in millions): $210,783;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $98,418;
Number of foreign subsidiaries: 45;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 23;
Bahamas (5);
Bermuda (16);
Liberia (1);
Singapore (1).
Corporation: Cisco Systems;
Rank by revenue: 70;
2007 Revenue (dollars in millions): $34,922;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $4,063;
Number of foreign subsidiaries: 201;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 38;
Barbados (1);
Bermuda (7);
Costa Rica (1);
Cyprus (1);
Hong Kong (5);
Ireland (8);
Jordan (1);
Latvia (1);
Luxembourg (2);
Mauritius (2);
Panama (1);
Singapore (6);
Switzerland (2).
Corporation: Citigroup;
Rank by revenue: 8;
2007 Revenue (dollars in millions): $159,229;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $3,122;
Number of foreign subsidiaries: 1,240;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 427;
Aruba (1);
Bahamas (16);
Bahrain (1);
Barbados (2);
Bermuda (19);
British Virgin Islands (35);
Cayman Islands (90);
Channel Islands (12);
Costa Rica (19);
Gibraltar (1);
Guernsey (1);
Hong Kong (40);
Ireland (16);
Isle of Man (1);
Jersey (21);
Luxembourg (91);
Macao (1);
Mauritius (15);
Panama (17);
St. Kitts and Nevis (1);
Singapore (18);
Switzerland (8);
Turks and Caicos Islands (1).
Corporation: Coca-Cola;
Rank by revenue: 81;
2007 Revenue (dollars in millions): $28,857;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $29,942;
Number of foreign subsidiaries: 72;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 8;
British Virgin Islands (1);
Cayman Islands (2);
Costa Rica (1);
Hong Kong (1);
Ireland (1);
Singapore (1);
Switzerland (1).
Corporation: Comcast;
Rank by revenue: 78;
2007 Revenue (dollars in millions): $30,895;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $3,118;
Number of foreign subsidiaries: 29;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 3;
Hong Kong (1);
Netherlands Antilles (1);
Switzerland (1).
Corporation: ConocoPhillips;
Rank by revenue: 5;
2007 Revenue (dollars in millions): $178,558;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $267,206;
Number of foreign subsidiaries: 125;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 44;
Bahamas (2);
Bermuda (17);
British Virgin Islands (2);
Cayman Islands (9);
Ireland (3);
Liberia (5);
Luxembourg (2);
Marshall Islands (1);
Singapore (1);
Switzerland (2).
Corporation: Costco Wholesale;
Rank by revenue: 29;
2007 Revenue (dollars in millions): $64,400;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $12;
Number of foreign subsidiaries: 3;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 1;
Bermuda (1).
Corporation: Countrywide Financial;
Rank by revenue: 98;
2007 Revenue (dollars in millions): $23,442;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: 0;
Number of foreign subsidiaries: 20;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 7;
Cayman Islands (1);
Costa Rica (1);
Guernsey (2);
Hong Kong (1);
Mauritius (1);
Singapore (1).
Corporation: CVS Caremark;
Rank by revenue: 24;
2007 Revenue (dollars in millions): $76,330;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $971;
Number of foreign subsidiaries: 0;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Corporation: Deere;
Rank by revenue: 96;
2007 Revenue (dollars in millions): $24,082;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $29,428;
Number of foreign subsidiaries: 32;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 3;
Luxembourg (2);
Switzerland (1).
Corporation: Dell, Inc.;
Rank by revenue: 33;
2007 Revenue (dollars in millions): $61,133;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $1,132,476;
Number of foreign subsidiaries: 158;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 29;
Bahrain (1);
Barbados (1);
Cayman Islands (4);
Costa Rica (2);
Hong Kong (1);
Ireland (10);
Lebanon (1);
Luxembourg (1);
Panama (1);
Singapore (5);
Switzerland (2).
Corporation: Delphi;
Rank by revenue: 88;
2007 Revenue (dollars in millions): $26,160;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $1,650;
Number of foreign subsidiaries: 141;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 9;
Ireland (1);
Luxembourg (3);
Singapore (3);
Virgin Islands (2)[B].
Corporation: Dow Chemical;
Rank by revenue: 41;
2007 Revenue (dollars in millions): $53,513;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $10,180;
Number of foreign subsidiaries: 317;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 35;
Bahrain (1);
Barbados (3);
Bermuda (3);
Costa Rica (1);
Hong Kong (5);
Ireland (3);
Luxembourg (3);
Mauritius (2);
Singapore (6);
Switzerland (7);
Virgin Islands (1)[B].
Corporation: DuPont;
Rank by revenue: 80;
2007 Revenue (dollars in millions): $30,653;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $3,386;
Number of foreign subsidiaries: 44;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 9;
Bermuda (2);
Hong Kong (1);
Luxembourg (2);
Singapore (1);
Switzerland (3).
Corporation: Enterprise GP Holdings;
Rank by revenue: 86;
2007 Revenue (dollars in millions): $26,714;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: 0;
Number of foreign subsidiaries: 1;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Corporation: Exxon Mobil Corporation;
Rank by revenue: 2;
2007 Revenue (dollars in millions): $372,824;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $949,152;
Number of foreign subsidiaries: 122;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 32;
Bahamas (18);
Bermuda (1);
Cayman Islands (3);
Hong Kong (3);
Ireland (1);
Luxembourg (2);
Singapore (3);
Switzerland (1).
Corporation: Fannie Mae;
Rank by revenue: 52;
2007 Revenue (dollars in millions): $43,355;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: 0;
Number of foreign subsidiaries: 0;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Corporation: FedEx;
Rank by revenue: 67;
2007 Revenue (dollars in millions): $35,214;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $59,453;
Number of foreign subsidiaries: 101;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 21;
Antigua (1);
Bahamas (1);
Barbados (1);
Bermuda (1);
Cayman Islands (3);
Costa Rica (1);
Grenada (1);
Hong Kong (2);
Ireland (3);
Netherlands Antilles (2);
Singapore (1);
St. Kitts (1); St. Lucia (1);
Turks and Caicos Islands (1);
U.S. Virgin Islands (1).
Corporation: Ford Motor Company;
Rank by revenue: 7;
2007 Revenue (dollars in millions): $172,468;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $358,360;
Number of foreign subsidiaries: 54;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 2;
Bermuda (1);
Cayman Islands (1).
Corporation: Freddie Mac;
Rank by revenue: 53;
2007 Revenue (dollars in millions): $43,104;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: 0;
Number of foreign subsidiaries: 0;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Corporation: General Dynamics Corporation;
Rank by revenue: 84;
2007 Revenue (dollars in millions): $27,294;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $13,905,516;
Number of foreign subsidiaries: 51;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 5;
Cyprus (1);
Singapore (1);
Switzerland (3).
Corporation: General Electric Company;
Rank by revenue: 6;
2007 Revenue (dollars in millions): $176,656;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $2,780,528;
Number of foreign subsidiaries: 40;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 7;
Bermuda (3);
Luxembourg (1);
Singapore (3).
Corporation: General Motors Corporation;
Rank by revenue: 4;
2007 Revenue (dollars in millions): $182,347;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $517,205;
Number of foreign subsidiaries: 113;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 11;
Barbados (1);
Bermuda (2);
Cayman Islands (4);
Ireland (1);
Singapore (1);
Switzerland (2).
Corporation: GMAC;
Rank by revenue: 77;
2007 Revenue (dollars in millions): $31,490;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: 0;
Number of foreign subsidiaries: 56;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 2;
Bermuda (1);
Switzerland (1).
Corporation: Goldman Sachs Group;
Rank by revenue: 20;
2007 Revenue (dollars in millions): $87,968;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $356;
Number of foreign subsidiaries: 55;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 29;
Bermuda (3);
British Virgin Islands (1);
Cayman Islands (15);
Hong Kong (3);
Ireland (1);
Jersey (1);
Mauritius (5).
Corporation: Hartford Financial Services;
Rank by revenue: 90;
2007 Revenue (dollars in millions): $25,916;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $353;
Number of foreign subsidiaries: 32;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 10;
Bermuda (7);
Ireland (3).
Corporation: Hess Corporation;
Rank by revenue: 76;
2007 Revenue (dollars in millions): $31,924;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $240,500;
Number of foreign subsidiaries: 11;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 5;
Cayman Islands (4);
U.S. Virgin Islands (1).
Corporation: Hewlett-Packard Company;
Rank by revenue: 14;
2007 Revenue (dollars in millions): $104,286;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $374,297;
Number of foreign subsidiaries: 81;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 14;
Cayman Islands (1);
Costa Rica (1);
Hong Kong (1);
Ireland (3);
Latvia (1);
Netherlands Antilles (1);
Singapore (4);
Switzerland (2).
Corporation: Home Depot;
Rank by revenue: 22;
2007 Revenue (dollars in millions): $84,740;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $2,304;
Number of foreign subsidiaries: 0;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Corporation: Honeywell International, Inc.;
Rank by revenue: 72;
2007 Revenue (dollars in millions): $34,589;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $2,491,103;
Number of foreign subsidiaries: 35;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 7;
Bermuda (1);
Luxembourg (3);
Singapore (1);
Switzerland (2).
Corporation: Humana;
Rank by revenue: 93;
2007 Revenue (dollars in millions): $25,290;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $37,863;
Number of foreign subsidiaries: 5;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Corporation: Ingram Micro;
Rank by revenue: 68;
2007 Revenue (dollars in millions): $35,047;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: 0;
Number of foreign subsidiaries: 104;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 33;
Barbados (1);
Bermuda (2);
British Virgin Islands (1);
Cayman Islands (8);
Hong Kong (6);
Luxembourg (1);
Mauritius (2);
Panama (1);
Singapore (10);
Switzerland (1).
Corporation: Intel;
Rank by revenue: 59;
2007 Revenue (dollars in millions): $38,334;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: 0;
Number of foreign subsidiaries: 15;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 6;
Cayman Islands (5);
Costa Rica (1).
Corporation: International Business Machines Corporation;
Rank by revenue: 15;
2007 Revenue (dollars in millions): $98,786;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $1,427,788;
Number of foreign subsidiaries: 70;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 10;
Bahamas (1);
Barbados (1);
Bermuda (1);
Costa Rica (1);
Hong Kong (1);
Ireland (1);
Latvia (1);
Luxembourg (1);
Singapore (1);
Switzerland (1).
Corporation: J.P. Morgan Chase & Co.;
Rank by revenue: 12;
2007 Revenue (dollars in millions): $116,353;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $55,337;
Number of foreign subsidiaries: 163;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 50;
Bahamas (1);
Bermuda (2);
British Virgin Islands (4);
Cayman Islands (7);
Channel Islands (4);
Hong Kong (8);
Ireland (2);
Luxembourg (8);
Mauritius (8);
Singapore (5);
Switzerland (1).
Corporation: Johnson & Johnson;
Rank by revenue: 34;
2007 Revenue (dollars in millions): $61,095;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $170,246;
Number of foreign subsidiaries: 175;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 38;
Hong Kong (2);
Ireland (16);
Luxembourg (1);
Panama (1);
Singapore (1);
Switzerland (17).
Corporation: Johnson Controls;
Rank by revenue: 71;
2007 Revenue (dollars in millions): $34,678;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $120,645;
Number of foreign subsidiaries: 0;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Corporation: Kraft Foods, Inc.;
Rank by revenue: 62;
2007 Revenue (dollars in millions): $37,241;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $348,708;
Number of foreign subsidiaries: 255;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 36;
Bahamas (1);
Bahrain (1);
British Virgin Islands (2);
Cayman Islands (1);
Costa Rica (3);
Hong Kong (4);
Ireland (4);
Latvia (1);
Liberia (2);
Luxembourg (2);
Panama (1);
Singapore (8);
Switzerland (6).
Corporation: Kroger;
Rank by revenue: 26;
2007 Revenue (dollars in millions): $70,235;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $86;
Number of foreign subsidiaries: 1;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 1;
Hong Kong (1).
Corporation: Lehman Brothers Holdings;
Rank by revenue: 36;
2007 Revenue (dollars in millions): $59,003;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $25;
Number of foreign subsidiaries: 141;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 57;
Bermuda (2);
Cayman Islands (31);
Hong Kong (9);
Ireland (1);
Luxembourg (6);
Mauritius (3);
Singapore (5).
Corporation: Lockheed Martin Corporation;
Rank by revenue: 56;
2007 Revenue (dollars in millions): $41,862;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $32,784,881;
Number of foreign subsidiaries: 0;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Corporation: Lowe's;
Rank by revenue: 47;
2007 Revenue (dollars in millions): $48,283;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $717;
Number of foreign subsidiaries: 0;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Corporation: Macy's;
Rank by revenue: 87;
2007 Revenue (dollars in millions): $26,340;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: 0;
Number of foreign subsidiaries: 0;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Corporation: Marathon Oil;
Rank by revenue: 35;
2007 Revenue (dollars in millions): $60,044;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $50;
Number of foreign subsidiaries: 115;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 76;
Bahamas (1);
Barbados (1);
Bermuda (3);
Cayman Islands (65);
Cyprus (1);
Ireland (2);
Liberia (1);
Luxembourg (1);
Switzerland (1).
Corporation: McDonald's;
Rank by revenue: 100;
2007 Revenue (dollars in millions): $23,231;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: 0;
Number of foreign subsidiaries: 34;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 5;
Hong Kong (2);
Switzerland (3).
Corporation: McKesson Corporation;
Rank by revenue: 18;
2007 Revenue (dollars in millions): $93,574;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $4,692,110;
Number of foreign subsidiaries: 1;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 1;
Ireland (1).
Corporation: Medco Health Solutions;
Rank by revenue: 50;
2007 Revenue (dollars in millions): $44,506;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $261;
Number of foreign subsidiaries: 0;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Corporation: Merck & Co., Inc.;
Rank by revenue: 95;
2007 Revenue (dollars in millions): $24,198;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $1,418,213;
Number of foreign subsidiaries: 199;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 44;
Barbados (2);
Bermuda (14);
Cyprus (1);
Hong Kong (3);
Ireland (7);
Latvia (1);
Lebanon (1);
Luxembourg (2);
Panama (2);
Singapore (6);
Switzerland (5).
Corporation: Merrill Lynch;
Rank by revenue: 30;
2007 Revenue (dollars in millions): $64,217;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $500;
Number of foreign subsidiaries: 82;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 21;
Bermuda (2);
Cayman Islands (3);
Hong Kong (4);
Ireland (2);
Luxembourg (1);
Mauritius (3);
Netherlands Antilles (1);
Singapore (2);
Switzerland (3).
Corporation: MetLife;
Rank by revenue: 42;
2007 Revenue (dollars in millions): $53,150;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $1,873;
Number of foreign subsidiaries: 84;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 19;
Barbados (5); Bermuda (3);
Cayman Islands (5);
Hong Kong (2);
Ireland (2);
Singapore (1);
Virgin Islands (1)[B].
Corporation: Microsoft;
Rank by revenue: 43;
2007 Revenue (dollars in millions): $51,122;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $48,717;
Number of foreign subsidiaries: 14;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 8;
Bermuda (2);
Ireland (5);
Singapore (1).
Corporation: Morgan Stanley;
Rank by revenue: 21;
2007 Revenue (dollars in millions): $87,879;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $14,062;
Number of foreign subsidiaries: 568;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 273;
Bermuda (3);
British Virgin Islands (1);
Cayman Islands (158);
Cyprus (2);
Gibraltar (2);
Hong Kong (15);
Ireland (6);
Jersey (19);
Liberia (5);
Luxembourg (29);
Malta (1);
Marshall Islands (14);
Mauritius (4);
Panama (1);
Singapore (9);
Switzerland (4).
Corporation: Motorola, Inc.;
Rank by revenue: 64;
2007 Revenue (dollars in millions): $36,622;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $321,347;
Number of foreign subsidiaries: 24;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 4;
Hong Kong (1);
Singapore (3).
Corporation: News Corporation;
Rank by revenue: 82;
2007 Revenue (dollars in millions): $28,655;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $2,646;
Number of foreign subsidiaries: 782;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 152;
Belize (1); Bermuda (1);
British Virgin Islands (62);
Cayman Islands (33);
Cyprus (1);
Hong Kong (21);
Ireland (1);
Latvia (4);
Luxembourg (4);
Marshall Islands (1);
Mauritius (15);
Panama (1);
Singapore (5);
Switzerland (2).
Corporation: Northrop Grumman Corporation;
Rank by revenue: 75;
2007 Revenue (dollars in millions): $32,032;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $15,991,673;
Number of foreign subsidiaries: 0;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Corporation: PepsiCo, Inc.;
Rank by revenue: 58;
2007 Revenue (dollars in millions): $39,474;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $218,353;
Number of foreign subsidiaries: 356;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 70;
Bahamas (1);
Barbados (1);
Bermuda (13);
Cayman Islands (2);
Costa Rica (2);
Cyprus (5);
Gibraltar (1);
Hong Kong (10);
Ireland (9);
Jordan (1);
Latvia (1);
Liechtenstein (1);
Luxembourg (7);
Mauritius (2);
Netherlands Antilles (6);
Panama (1);
Singapore (1);
Switzerland (6).
Corporation: Pfizer;
Rank by revenue: 46;
2007 Revenue (dollars in millions): $48,418;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $40,609;
Number of foreign subsidiaries: 356;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 80;
Bahamas (1);
Bermuda (3);
Cayman Islands (1);
Costa Rica (2);
Guernsey (1);
Hong Kong (4);
Ireland (28);
Jersey (10);
Luxembourg (16);
Panama (3);
Singapore (6);
Switzerland (4);
Virgin Islands (1)[B].
Corporation: The Procter & Gamble Company;
Rank by revenue: 23;
2007 Revenue (dollars in millions): $76,476;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $312,828;
Number of foreign subsidiaries: 581;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 83;
Barbados (1);
Belize (1);
Bermuda (5);
British Virgin Islands (2);
Cayman Islands (2);
Costa Rica (3);
Hong Kong (10);
Ireland (11);
Latvia (1);
Lebanon (2);
Liechtenstein (1);
Luxembourg (6);
Panama (3);
Singapore (11);
Switzerland (24).
Corporation: Prudential Financial;
Rank by revenue: 73;
2007 Revenue (dollars in millions): $34,401;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $35,768;
Number of foreign subsidiaries: 116;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 27;
Barbados (1);
Bermuda (9);
Cayman Islands (5);
Hong Kong (7);
Ireland (1);
Luxembourg (1);
Singapore (3).
Corporation: Safeway;
Rank by revenue: 54;
2007 Revenue (dollars in millions): $42,286;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $141;
Number of foreign subsidiaries: 18;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 4;
Bermuda (1);
British Virgin Islands (1);
Hong Kong (1);
Macao (1).
Corporation: Sears Holdings;
Rank by revenue: 44;
2007 Revenue (dollars in millions): $50,703;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $315;
Number of foreign subsidiaries: 2;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 1;
Bermuda (1).
Corporation: Sprint Nextel Corporation;
Rank by revenue: 57;
2007 Revenue (dollars in millions): $40,146;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $142,754;
Number of foreign subsidiaries: 59;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 7;
Bermuda (1);
Hong Kong (2);
Ireland (1);
Singapore (1);
Switzerland (2).
Corporation: Sunoco;
Rank by revenue: 55;
2007 Revenue (dollars in millions): $42,101;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $68;
Number of foreign subsidiaries: 11;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 5;
Bermuda (4);
Panama (1).
Corporation: SuperValu;
Rank by revenue: 61;
2007 Revenue (dollars in millions): $37,406;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $1,520;
Number of foreign subsidiaries: 6;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 5;
Bermuda (4);
Cayman Islands (1).
Corporation: SYSCO Corporation;
Rank by revenue: 69;
2007 Revenue (dollars in millions): $35,042;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $173,586;
Number of foreign subsidiaries: 31;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 1;
Hong Kong (1).
Corporation: Target;
Rank by revenue: 31;
2007 Revenue (dollars in millions): $63,367;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: 0;
Number of foreign subsidiaries: 19;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 8;
Bermuda (1);
Hong Kong (6);
Singapore (1).
Corporation: Tech Data;
Rank by revenue: 99;
2007 Revenue (dollars in millions): $23,423;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: 0;
Number of foreign subsidiaries: 67;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 7;
Cayman Islands (1);
Costa Rica (1);
Ireland (1);
Luxembourg (1);
Netherlands Antilles (1);
Switzerland (2).
Corporation: Time Warner;
Rank by revenue: 48;
2007 Revenue (dollars in millions): $46,615;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $7,575;
Number of foreign subsidiaries: 48;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 4;
Hong Kong (2);
Ireland (1);
Luxembourg (1).
Corporation: Travelers Companies;
Rank by revenue: 89;
2007 Revenue (dollars in millions): $26,017;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $535;
Number of foreign subsidiaries: 27;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 6;
Bermuda (4);
Cayman Islands (1);
Singapore (1).
Corporation: Tyson Foods, Inc.;
Rank by revenue: 85;
2007 Revenue (dollars in millions): $26,900;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $326,553;
Number of foreign subsidiaries: 41;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 6;
Bermuda (1);
Cayman Islands (1);
Gibraltar (1);
Hong Kong (1);
Luxembourg (2).
Corporation: United Parcel Service, Inc.;
Rank by revenue: 45;
2007 Revenue (dollars in millions): $49,692;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $140,771;
Number of foreign subsidiaries: 0;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Corporation: United Technologies Corporation;
Rank by revenue: 38;
2007 Revenue (dollars in millions): $54,759;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $5,714,807;
Number of foreign subsidiaries: 93;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 12;
Cayman Islands (1);
Hong Kong (2);
Ireland (1);
Luxembourg (4);
Singapore (4).
Corporation: UnitedHealth Group;
Rank by revenue: 25;
2007 Revenue (dollars in millions): $75,431;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $1,524;
Number of foreign subsidiaries: 54;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 11;
Bermuda (1);
Cayman Islands (2);
Costa Rica (2);
Hong Kong (2);
Ireland (2);
Mauritius (1);
Singapore (1).
Corporation: Valero Energy Corporation;
Rank by revenue: 16;
2007 Revenue (dollars in millions): $96,758;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $1,027,334;
Number of foreign subsidiaries: 23;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 11;
Aruba (5);
Bermuda (1);
British Virgin Islands (3);
Cayman Islands (2).
Corporation: Verizon Communications, Inc.;
Rank by revenue: 17;
2007 Revenue (dollars in millions): $93,775;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $428,654;
Number of foreign subsidiaries: 0;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Corporation: Wachovia Corporation;
Rank by revenue: 37;
2007 Revenue (dollars in millions): $55,528;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $3,683;
Number of foreign subsidiaries: 105;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 59;
Aruba (1);
Barbados (1);
Bermuda (18);
British Virgin Islands (3);
Cayman Islands (16);
Guernsey (1);
Hong Kong (9);
Ireland (2);
Mauritius (3);
Singapore (2);
Turks and Caicos Islands (1);
U.S. Virgin Islands (2).
Corporation: Walgreen;
Rank by revenue: 39;
2007 Revenue (dollars in millions): $53,762;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $17;
Number of foreign subsidiaries: 4;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 2;
Mauritius (2).
Corporation: Wal-Mart Stores;
Rank by revenue: 1;
2007 Revenue (dollars in millions): $378,799;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $173;
Number of foreign subsidiaries: 1;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Corporation: Walt Disney;
Rank by revenue: 66;
2007 Revenue (dollars in millions): $35,882;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $1,224;
Number of foreign subsidiaries: 15;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 3;
Hong Kong (2);
Switzerland (1).
Corporation: Washington Mutual;
Rank by revenue: 92;
2007 Revenue (dollars in millions): $25,531;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $556;
Number of foreign subsidiaries: 5;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 3;
Hong Kong (1);
Mauritius (1);
Virgin Islands (1)[B].
Corporation: WellPoint;
Rank by revenue: 32;
2007 Revenue (dollars in millions): $61,134;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $72,575;
Number of foreign subsidiaries: 3;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 1;
Bermuda (1).
Corporation: Wells Fargo;
Rank by revenue: 40;
2007 Revenue (dollars in millions): $53,593;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $37,777;
Number of foreign subsidiaries: 34;
Number and location(s) of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 18;
Barbados (1);
Cayman Islands (9);
Hong Kong (4);
Mauritius (4).
Sources: Fortune 500 list for 2008 (which is based on 2007 revenues),
USASpending.gov, Exhibit 21s filed with the Securities and Exchange
Commission, and jurisdictions listed as tax havens or financial privacy
jurisdictions.
[A] Federal contract obligations are estimates. The actual contract
obligations may be greater.
[B] Abbot Laboratories, Delphi, Dow Chemical, MetLife, Pfizer, and
Washington Mutual did not differentiate between the U.S. Virgin Islands
and the British Virgin Islands. Therefore, for the purpose of this
list, they are listed as Virgin Islands.
[End of table]
[End of section]
Appendix III: The 100 Largest Publicly Traded U.S. Federal Contractors:
Contractor: AAR Corporation;
Rank by federal contract obligations: 79;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $196,565;
Number of foreign subsidiaries: 0;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: AECOM Technology;
Rank by federal contract obligations: 48;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $417,324;
Number of foreign subsidiaries: 0;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: AeroVironment, Inc.;
Rank by federal contract obligations: 83;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $185,261;
Number of foreign subsidiaries: 0;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: Affiliated Computer Services, Inc.;
Rank by federal contract obligations: 72;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $218,586;
Number of foreign subsidiaries: 55;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 7;
Barbados (1);
Hong Kong (2);
Ireland (1);
Luxembourg (1);
Switzerland (2).
Contractor: Alliant Techsystems, Inc.;
Rank by federal contract obligations: 24;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $1,422,471;
Number of foreign subsidiaries: 0;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: AmerisourceBergen Corporation;
Rank by federal contract obligations: 21;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $1,469,378;
Number of foreign subsidiaries: 0;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: Archer-Daniels-Midland Company;
Rank by federal contract obligations: 78;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $197,488;
Number of foreign subsidiaries: 6;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 3;
Cayman Islands (2);
Ireland (1).
Contractor: AT&T, Inc.;
Rank by federal contract obligations: 40;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $519,233;
Number of foreign subsidiaries: 0;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: BearingPoint, Inc.;
Rank by federal contract obligations: 38;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $520,725;
Number of foreign subsidiaries: 106;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 28;
Aruba (2);
Barbados (1);
Bermuda (11);
British Virgin Islands (2);
Cayman Islands (2);
Costa Rica (1);
Jordan (1); Ireland (1);
Panama (1); Switzerland (1);
Singapore (4);
U.S. Virgin Islands (1).
Contractor: Berkshire Hathaway, Inc.;
Rank by federal contract obligations: 70;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $235,394;
Number of foreign subsidiaries: 27;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 1;
Ireland (1).
Contractor: The Boeing Company;
Rank by federal contract obligations: 2;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $23,312,965;
Number of foreign subsidiaries: 135;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 38;
Bermuda (6);
Cayman Islands (1);
Gibraltar (2);
Hong Kong (4);
Ireland (4);
Netherlands Antilles (2);
Singapore (3);
U.S. Virgin Islands (16).
Contractor: CACI International, Inc.;
Rank by federal contract obligations: 22;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $1,443,230;
Number of foreign subsidiaries: 1;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: Cardinal Health, Inc.;
Rank by federal contract obligations: 30;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $1,039,243;
Number of foreign subsidiaries: 135;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 23;
Barbados (1);
Bermuda (2);
British Virgin Islands (1);
Cayman Islands (1);
Hong Kong (1);
Ireland (5);
Luxembourg (3);
Malta (1);
Mauritius (1);
Singapore (3);
Switzerland (4).
Contractor: Caterpillar, Inc.;
Rank by federal contract obligations: 89;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $171,485;
Number of foreign subsidiaries: 331;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 49;
Barbados (1);
Bermuda (13);
Costa Rica (1);
Guernsey (1);
Hong Kong (3);
Ireland (2);
Luxembourg (3);
Mauritius (1);
Panama (3);
Singapore (8);
Switzerland (13).
Contractor: Ceradyne, Inc.;
Rank by federal contract obligations: 43;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $463,590;
Number of foreign subsidiaries: 7;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 2;
Cayman Islands (1);
Hong Kong (1).
Contractor: Computer Sciences Corporation;
Rank by federal contract obligations: 10;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $3,189,701;
Number of foreign subsidiaries: 119;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 21;
Bermuda (1);
British Virgin Islands (4);
Costa Rica (1);
Hong Kong (5);
Ireland (2);
Luxembourg (2);
Macao (1);
Singapore (4);
Switzerland (1).
Contractor: Comtech Telecommunications Corporation;
Rank by federal contract obligations: 62;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $286,461;
Number of foreign subsidiaries: 1;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: ConAgra Foods, Inc.;
Rank by federal contract obligations: 97;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $148,713;
Number of foreign subsidiaries: 2;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: ConocoPhillips;
Rank by federal contract obligations: 65;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $267,206;
Number of foreign subsidiaries: 125;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 44;
Bahamas (2);
Bermuda (17);
British Virgin Islands (2);
Cayman Islands (9);
Ireland (3);
Liberia (5);
Luxembourg (2);
Marshall Islands (1);
Singapore (1);
Switzerland (2).
Contractor: Constellation Energy Group, Inc.;
Rank by federal contract obligations: 91;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $166,060;
Number of foreign subsidiaries: 0;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: Cornell Companies, Inc.;
Rank by federal contract obligations: 63;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $282,588;
Number of foreign subsidiaries: 0;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: Corrections Corporation of America;
Rank by federal contract obligations: 46;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $447,008;
Number of foreign subsidiaries: 2;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: Cubic Corporation;
Rank by federal contract obligations: 52;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $359,911;
Number of foreign subsidiaries: 8;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 1;
U.S. Virgin Islands (1).
Contractor: Danaher Corporation;
Rank by federal contract obligations: 98;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $147,214;
Number of foreign subsidiaries: 548;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 72;
Barbados (1);
Cayman Islands (9);
Hong Kong (14);
Ireland (5);
Luxembourg (4);
Malta (1);
Mauritius (2);
Singapore (13);
St. Kitts and Nevis (1);
Switzerland (22).
Contractor: Dell, Inc.;
Rank by federal contract obligations: 28;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $1,132,476;
Number of foreign subsidiaries: 158;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 29;
Bahrain (1);
Barbados (1);
Cayman Islands (4);
Costa Rica (2);
Hong Kong (1);
Ireland (10);
Lebanon (1);
Luxembourg (1);
Panama (1);
Singapore (5);
Switzerland (2).
Contractor: DRS Technologies, Inc.;
Rank by federal contract obligations: 18;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $1,795,032;
Number of foreign subsidiaries: 9;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: Eaton Corporation;
Rank by federal contract obligations: 87;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $173,671;
Number of foreign subsidiaries: 164;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 37;
Barbados (2);
Bermuda (4);
British Virgin Islands (3);
Cayman Islands (5);
Costa Rica (1);
Hong Kong (4);
Ireland (1);
Luxembourg (5);
Mauritius (4);
Netherlands Antilles (1);
Singapore (5);
Switzerland (2).
Contractor: Electronic Data Systems Corporation;
Rank by federal contract obligations: 17;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $2,312,022;
Number of foreign subsidiaries: 137;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 19;
Bahrain (1);
Bermuda (1);
British Virgin Islands (1);
Cayman Islands (2);
Costa Rica (1);
Guernsey (1);
Hong Kong (1);
Ireland (1);
Luxembourg (2);
Mauritius (2);
Panama (1);
Singapore (3);
Switzerland (2).
Contractor: Emergent Biosolutions, Inc.;
Rank by federal contract obligations: 45;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $448,352;
Number of foreign subsidiaries: 5;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 1;
Singapore (1).
Contractor: Exxon Mobil Corporation;
Rank by federal contract obligations: 32;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $949,152;
Number of foreign subsidiaries: 122;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 32;
Bahamas (18);
Bermuda (1);
Cayman Islands (3);
Hong Kong (3);
Ireland (1);
Luxembourg (2);
Singapore (3);
Switzerland (1).
Contractor: Flir Systems, Inc.[B];
Rank by federal contract obligations: 67;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $249,658;
Number of foreign subsidiaries: Unknown;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: Unknown.
Contractor: Fluor Corporation;
Rank by federal contract obligations: 20;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $1,506,242;
Number of foreign subsidiaries: 197;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 34;
Barbados (2);
Bermuda (7);
British Virgin Islands (2);
Cyprus (2);
Guernsey (9);
Ireland (5);
Liechtenstein (2);
Mauritius (3);
Panama (1);
St. Lucia (1).
Contractor: Force Protection, Inc.;
Rank by federal contract obligations: 27;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $1,139,550;
Number of foreign subsidiaries: 0;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: Ford Motor Company;
Rank by federal contract obligations: 53;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $358,360;
Number of foreign subsidiaries: 54;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 2;
Bermuda (1);
Cayman Islands (1).
Contractor: General Dynamics Corporation;
Rank by federal contract obligations: 4;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $13,905,516;
Number of foreign subsidiaries: 51;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 5;
Cyprus (1);
Singapore (1);
Switzerland (3).
Contractor: General Electric Company;
Rank by federal contract obligations: 11;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $2,780,528;
Number of foreign subsidiaries: 40;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 7;
Bermuda (3);
Luxembourg (1);
Singapore (3).
Contractor: General Mills, Inc.;
Rank by federal contract obligations: 81;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $193,621;
Number of foreign subsidiaries: 171;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 33;
Aruba (1);
Bermuda (5);
British Virgin Islands (2);
Gibraltar (1);
Hong Kong (5);
Lebanon (2);
Luxembourg (1);
Mauritius (2);
Netherlands Antilles (1);
Panama (1);
Singapore (4);
Switzerland (8).
Contractor: General Motors Corporation;
Rank by federal contract obligations: 41;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $517,205;
Number of foreign subsidiaries: 113;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 11;
Barbados (1);
Bermuda (2);
Cayman Islands (4);
Ireland (1);
Singapore (1);
Switzerland (2).
Contractor: Goodrich Corporation;
Rank by federal contract obligations: 56;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $326,475;
Number of foreign subsidiaries: 72;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 17;
Barbados (2);
Gibraltar (3);
Hong Kong (1);
Luxembourg (5);
Mauritius (1);
Singapore (4);
Virgin Islands (1)[C].
Contractor: The Goodyear Tire & Rubber Company;
Rank by federal contract obligations: 85;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $182,072;
Number of foreign subsidiaries: 165;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 13;
Bermuda (1);
Ireland (2);
Luxembourg (6);
Mauritius (1);
Singapore (2);
Switzerland (1).
Contractor: Great Lakes Dredge & Dock Corporation;
Rank by federal contract obligations: 68;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $246,606;
Number of foreign subsidiaries: 0;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: GTSI Corporation;
Rank by federal contract obligations: 49;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $399,060;
Number of foreign subsidiaries: 0;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: Harris Corporation;
Rank by federal contract obligations: 19;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $1,741,545;
Number of foreign subsidiaries: 71;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 13;
Bermuda (1);
Cayman Islands (1);
Hong Kong (5);
Mauritius (1);
Singapore (4);
U.S. Virgin Islands (1).
Contractor: Hess Corporation; Rank by federal contract obligations: 69;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: 240,500; Number of foreign subsidiaries: 11; Number and
locations of subsidiaries in jurisdictions listed as tax havens or
financial privacy jurisdictions: 5; Cayman Islands (4); U.S. Virgin
Islands (1).
Contractor: Hewlett-Packard Company;
Rank by federal contract obligations: 50;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $374,297;
Number of foreign subsidiaries: 81;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 14;
Cayman Islands (1);
Costa Rica (1);
Hong Kong (1);
Ireland (3);
Latvia (1);
Netherlands Antilles (1);
Singapore (4);
Switzerland (2).
Contractor: Honeywell International, Inc.;
Rank by federal contract obligations: 13;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $2,491,103;
Number of foreign subsidiaries: 35;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 7;
Bermuda (1);
Luxembourg (3);
Singapore (1);
Switzerland (2).
Contractor: ICF International, Inc.;
Rank by federal contract obligations: 92;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $165,488;
Number of foreign subsidiaries: 7;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: International Business Machines Corporation;
Rank by federal contract obligations: 23;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $1,427,788;
Number of foreign subsidiaries: 70;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 10;
Bahamas (1);
Barbados (1);
Bermuda (1);
Costa Rica (1);
Hong Kong (1);
Ireland (1);
Latvia (1);
Luxembourg (1);
Singapore (1);
Switzerland (1).
Contractor: International Shipholding Corporation;
Rank by federal contract obligations: 94;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $162,236;
Number of foreign subsidiaries: 13;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 11;
Bermuda (1);
British Virgin Islands (4);
Cayman Islands (1);
Marshall Islands (2);
Panama (1);
Singapore (2).
Contractor: Interpublic Group of Companies, Inc.;
Rank by federal contract obligations: 44;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $462,229;
Number of foreign subsidiaries: 120;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 5;
Ireland (1);
Luxembourg (1);
Mauritius (1);
Singapore (1);
Switzerland (1).
Contractor: ITT Corporation;
Rank by federal contract obligations: 14;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $2,377,121;
Number of foreign subsidiaries: 170;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 18;
Barbados (1);
Bermuda (1);
Cayman Islands (1);
Hong Kong (3);
Ireland (3);
Luxembourg (5);
Singapore (2);
Switzerland (1);
Virgin Islands (1)[C].
Contractor: Jacobs Engineering Group, Inc.;
Rank by federal contract obligations: 29;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $1,051,891;
Number of foreign subsidiaries: 58;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 11;
Hong Kong (1);
Ireland (2);
Luxembourg (1);
Singapore (5);
U.S. Virgin Islands (1);
Virgin Islands (1)[C].
Contractor: Johnson & Johnson;
Rank by federal contract obligations: 90;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $170,246;
Number of foreign subsidiaries: 175;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 38;
Hong Kong (2);
Ireland (16);
Luxembourg (1);
Panama (1);
Singapore (1);
Switzerland (17).
Contractor: KBR, Inc.;
Rank by federal contract obligations: 8;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $4,794,248;
Number of foreign subsidiaries: 5;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: Kraft Foods, Inc.;
Rank by federal contract obligations: 54;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $348,708;
Number of foreign subsidiaries: 255;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 36;
Bahamas (1);
Bahrain (1);
British Virgin Islands (2);
Cayman Islands (1);
Costa Rica (3);
Hong Kong (4);
Ireland (4);
Latvia (1);
Liberia (2);
Luxembourg (2);
Panama (1);
Singapore (8);
Switzerland (6).
Contractor: L-3 Communications Holdings, Inc.;
Rank by federal contract obligations: 6;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $6,636,283;
Number of foreign subsidiaries: 90;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 15;
Barbados (1);
Bermuda (1);
Cayman Islands (1);
Costa Rica (1);
Hong Kong (2);
Ireland (1);
Singapore (5);
U.S. Virgin Islands (3).
Contractor: Lockheed Martin Corporation;
Rank by federal contract obligations: 1;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $32,784,881;
Number of foreign subsidiaries: 0;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: Mantech International Corporation;
Rank by federal contract obligations: 37;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $546,746;
Number of foreign subsidiaries: 7;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 1;
Panama (1).
Contractor: McDermott International, Inc.;
Rank by federal contract obligations: 77;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $199,070;
Number of foreign subsidiaries: 5;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 5;
Panama (5).
Contractor: McKesson Corporation;
Rank by federal contract obligations: 9;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $4,692,110;
Number of foreign subsidiaries: 1;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 1;
Ireland (1).
Contractor: Merck & Co., Inc.;
Rank by federal contract obligations: 25;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $1,418,213;
Number of foreign subsidiaries: 199;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 44;
Barbados (2);
Bermuda (14);
Cyprus (1);
Hong Kong (3);
Ireland (7);
Latvia (1);
Lebanon (1);
Luxembourg (2);
Panama (2);
Singapore (6);
Switzerland (5).
Contractor: Motorola, Inc.;
Rank by federal contract obligations: 58;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $321,347;
Number of foreign subsidiaries: 24;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 4;
Hong Kong (1);
Singapore (3).
Contractor: Navistar International Corporation;
Rank by federal contract obligations: 61;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $304,016;
Number of foreign subsidiaries: 4;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 1;
Cayman Islands (1).
Contractor: NCI, Inc.;
Rank by federal contract obligations: 75;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $208,545;
Number of foreign subsidiaries: 0;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: Northrop Grumman Corporation;
Rank by federal contract obligations: 3;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $15,991,673;
Number of foreign subsidiaries: 0;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: Olin Corporation;
Rank by federal contract obligations: 64;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $271,445;
Number of foreign subsidiaries: 7;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 1;
Bermuda (1).
Contractor: Oracle Corporation;
Rank by federal contract obligations: 93;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $164,665;
Number of foreign subsidiaries: 297;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 77;
Barbados (3); Bermuda (1);
British Virgin Islands (1);
Cayman Islands (5);
Costa Rica (1);
Cyprus (1);
Hong Kong (12);
Ireland (22);
Isle of Man (1);
Jersey (1);
Luxembourg (6);
Mauritius (1);
Netherlands Antilles (1);
Singapore (16);
Switzerland (5).
Contractor: Orbital Sciences Corporation;
Rank by federal contract obligations: 96;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $158,483;
Number of foreign subsidiaries: 0;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: Oshkosh Truck Corporation;
Rank by federal contract obligations: 16;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $2,339,964;
Number of foreign subsidiaries: 52;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 6;
Barbados (2);
Cayman Islands (2);
Hong Kong (1);
Mauritius (1).
Contractor: Owens & Minor, Inc.;
Rank by federal contract obligations: 66;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $257,284;
Number of foreign subsidiaries: 1;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 1;
British Virgin Islands (1).
Contractor: Pepco Holdings, Inc.;
Rank by federal contract obligations: 71;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $234,070;
Number of foreign subsidiaries: 0;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: PepsiCo, Inc.;
Rank by federal contract obligations: 73;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $218,353;
Number of foreign subsidiaries: 356;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 70;
Bahamas (1);
Barbados (1);
Bermuda (13);
Cayman Islands (2);
Costa Rica (2);
Cyprus (5);
Gibraltar (1);
Hong Kong (10);
Ireland (9);
Jordan (1);
Latvia (1);
Liechtenstein (1);
Luxembourg (7);
Mauritius (2);
Netherlands Antilles (6);
Panama (1);
Singapore (1);
Switzerland (6).
Contractor: Perot Systems Corporation;
Rank by federal contract obligations: 60;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $312,643;
Number of foreign subsidiaries: 38;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 13;
Bermuda (2);
Hong Kong (1);
Ireland (2);
Luxembourg (1);
Mauritius (1);
Singapore (3);
Switzerland (3).
Contractor: Point Blank Solutions, Inc.;
Rank by federal contract obligations: 76;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $206,202;
Number of foreign subsidiaries: 0;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: The Procter & Gamble Company;
Rank by federal contract obligations: 59;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $312,828;
Number of foreign subsidiaries: 581;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 83;
Barbados (1);
Belize (1);
Bermuda (5);
British Virgin Islands (2);
Cayman Islands (2);
Costa Rica (3);
Hong Kong (10);
Ireland (11);
Latvia (1);
Lebanon (2);
Liechtenstein (1);
Luxembourg (6);
Panama (3);
Singapore (11);
Switzerland (24).
Contractor: Raytheon Company;
Rank by federal contract obligations: 5;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $11,793,187;
Number of foreign subsidiaries: 0;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: Res-Care, Inc.;
Rank by federal contract obligations: 95;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $160,359;
Number of foreign subsidiaries: 0;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: Rockwell Collins, Inc.;
Rank by federal contract obligations: 26;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $1,219,054;
Number of foreign subsidiaries: 20;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 4;
Bermuda (2);
Luxembourg (1);
Singapore (1).
Contractor: The Shaw Group, Inc.[B];
Rank by federal contract obligations: 42;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $491,729;
Number of foreign subsidiaries: Unknown;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: Unknown.
Contractor: SI International, Inc.[B];
Rank by federal contract obligations: 82;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $191,954;
Number of foreign subsidiaries: Unknown;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: Unknown.
Contractor: Sprint Nextel Corporation;
Rank by federal contract obligations: 99;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $142,754;
Number of foreign subsidiaries: 59;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 7;
Bermuda (1);
Hong Kong (2);
Ireland (1);
Singapore (1);
Switzerland (2).
Contractor: SRA International, Inc.;
Rank by federal contract obligations: 35;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $661,871;
Number of foreign subsidiaries: 10;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: Stanley, Inc.;
Rank by federal contract obligations: 57;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $321,922;
Number of foreign subsidiaries: 0;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: SYSCO Corporation;
Rank by federal contract obligations: 88;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $173,586;
Number of foreign subsidiaries: 31;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 1;
Hong Kong (1).
Contractor: Teledyne, Inc.;
Rank by federal contract obligations: 51;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $372,709;
Number of foreign subsidiaries: 15;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 2;
Bermuda (1);
Singapore (1).
Contractor: Telos Corporation;
Rank by federal contract obligations: 84;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $183,777;
Number of foreign subsidiaries: 0;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: Tesoro Corporation;
Rank by federal contract obligations: 74;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $210,342;
Number of foreign subsidiaries: 0;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: Tetra Tech, Inc.;
Rank by federal contract obligations: 36;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $604,922;
Number of foreign subsidiaries: 6;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 1;
British Virgin Islands (1).
Contractor: Textron, Inc.;
Rank by federal contract obligations: 15;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $2,364,772;
Number of foreign subsidiaries: 98;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 5;
Barbados (1);
Singapore (2);
Switzerland (2).
Contractor: Tyson Foods, Inc.;
Rank by federal contract obligations: 55;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $326,553;
Number of foreign subsidiaries: 41;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 6;
Bermuda (1);
Cayman Islands (1);
Gibraltar (1);
Hong Kong (1);
Luxembourg (2).
Contractor: Unisys Corporation;
Rank by federal contract obligations: 33;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $807,003;
Number of foreign subsidiaries: 3;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: United Parcel Service, Inc.;
Rank by federal contract obligations: 100;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $140,771;
Number of foreign subsidiaries: 0;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: United Technologies Corporation;
Rank by federal contract obligations: 7;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $5,714,807;
Number of foreign subsidiaries: 93;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 12;
Cayman Islands (1);
Hong Kong (2);
Ireland (1);
Luxembourg (4);
Singapore (4).
Contractor: URS Corporation;
Rank by federal contract obligations: 12;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $2,643,385;
Number of foreign subsidiaries: 276;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 24;
Bahrain (2);
Bermuda (4);
Hong Kong (2);
Ireland (2);
Jordan (4);
Singapore (4);
U.S. Virgin Islands (2);
Virgin Islands (4)[C].
Contractor: Valero Energy Corporation;
Rank by federal contract obligations: 31;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $1,027,334;
Number of foreign subsidiaries: 23;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 11;
Aruba (5);
Bermuda (1);
British Virgin Islands (3);
Cayman Islands (2).
Contractor: Verizon Communications, Inc.;
Rank by federal contract obligations: 47;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $428,654;
Number of foreign subsidiaries: 0;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: Viasat, Inc.;
Rank by federal contract obligations: 80;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $195,071;
Number of foreign subsidiaries: 5;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 1;
Switzerland (1).
Contractor: VSE Corporation;
Rank by federal contract obligations: 34;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $706,444;
Number of foreign subsidiaries: 0;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 0.
Contractor: Wyeth-Ayerst International, Inc.;
Rank by federal contract obligations: 39;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $519,750;
Number of foreign subsidiaries: 32;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 4;
Ireland (2);
Singapore (1);
Switzerland (1).
Contractor: Xerox Corporation;
Rank by federal contract obligations: 86;
Federal contract obligations for fiscal year 2007 (dollars in
thousands)[A]: $179,963;
Number of foreign subsidiaries: 164;
Number and locations of subsidiaries in jurisdictions listed as tax
havens or financial privacy jurisdictions: 33;
Barbados (4);
Bermuda (8);
Hong Kong (1);
Ireland (12);
Jersey (1);
Luxembourg (2);
Mauritius (1);
Singapore (1);
Switzerland (2);
Turks and Caicos Islands (1).
Sources: USASpending.gov, Exhibit 21s filed with the SEC, and
jurisdictions listed as tax havens or financial privacy jurisdictions.
[A] Federal contract obligations are estimates. The actual contract
obligations may be greater.
[B] Flir Systems, Inc. did not list locations for some subsidiaries and
The Shaw Group, Inc. and SI International, Inc. did not list locations
for any subsidiaries.
[C] Goodrich Corporation, ITT Corporation, Jacobs Engineering Group,
Inc., and URS Corporation did not always differentiate between the U.S.
Virgin Islands and the British Virgin Islands. Therefore, for the
purpose of this list, they are listed as Virgin Islands.
[End of table]
[End of section]
Appendix IV: Comments from the Department of the Treasury:
Department Of The Treasury:
Washington, D.C, 20220:
Mr. James R. White:
Director, Tax Issues:
Strategic Issues Team
General Accountability Office:
441 G St., NW:
Washington, DC 20548:
Dear Mr. White:
The Treasury Department takes offshore tax evasion by individuals and
corporations very seriously, and has taken strong administrative and
regulatory steps to address the problem. In addition, the Treasury
Department will continue to expand our tax treaty and tax information
exchange agreement network so that the United States can obtain the
information about individuals and corporations and the administrative
assistance from other countries that the United States needs to enforce
its tax laws. In the "Declaration of the Summit on Financial Markets
and the World Economy," released on November 15, 2008, the Leaders of
the Group of Twenty, which includes the United States, reiterated the
need to "continue efforts to promote tax information exchange" and that
"[Hack of transparency and a failure to exchange tax information should
be vigorously addressed." The United States has long been a leader in
encouraging tax information exchange and greater transparency, and will
continue to be so.
We remain concerned, however, about the use of lists of so-called "tax
havens." In the draft report entitled "International Taxation: Large
U.S. Corporations and Federal Contractors with Subsidiaries in
Jurisdictions Listed as Tax Havens or Financial Privacy Jurisdictions"
(GAO-09-157), the Government Accountability Office (GAO) correctly
notes that there is no agreed-upon definition of tax haven or list of
jurisdictions that should be considered tax havens. Nonetheless, the
draft report proceeds to characterize jurisdictions as tax havens by
including them on a tax havens list. Although the report asserts that
the GAO did not develop its own definition of tax haven or its own list
of jurisdictions, the GAO does indeed produce such a list in the draft
report, compiled from three other lists.
One list used in the draft report is that released in 2000 by the
Organisation for Economic Co-operation and Development (OECD) of
jurisdictions that have committed to improving transparency and
effective exchange of information for tax matters and jurisdictions
that have not made such a commitment. Since that list of jurisdictions
was released, however, the vast majority of listed jurisdictions have
committed to meeting OECD standards of transparency and effective
exchange of information Moreover, many of the jurisdictions on that
2000 OECD list have signed tax information exchange agreements with the
United States. Thus, the 2000 OECD list includes countries from which
we can obtain information and that have committed to establishing
effective information exchange. Although the draft report acknowledges
that the list is outdated, the report surprisingly rises the lack of
any "updated" list from the OECD as the rationale for using the out-of-
date list.
In addition to using a list produced by the National Bureau of Economic
Research (NBER). the GAO also uses an Internal Revenue Service (IRS)
"John Doe" summons issued in 2005 to compile its "tax havens" list. Use
of the IRS summons is particularly problematic. The IRS summons lists
34 jurisdictions from which the IRS was seeking information about
individuals who had signature authority over bank accounts or credit
cards issued by, through, or on behalf of financial institutions in
those jurisdictions. The list of jurisdictions in that summons was put
together for a very specific purpose and was not at all intended to
suggest a general list of jurisdictions that the Treasury Department
and IRS consider tax havens. Moreover, the specific nature of the John
Doe summons - which focused on individual taxpayers - makes use of the
list of countries in that summons all the more inapposite since the
draft GAO report deals not with individuals but with foreign
subsidiaries of U.S. corporations. Because the problems identified in
the draft report and the John Doe summons are so different, it is
unclear what relevance the list of countries in the John Doe summons
has in the context of the report. For those reasons, we requested that
the GAO not use the summons list as a source for its tax havens list.
Moreover, we are concerned that such use will lead others to believe
that the Treasury Department intended the summons list to be a list of
tax havens.
Although the Treasury Department appreciates the GAO's efforts to
simplify what is a complex area, oversimplification can lead to
misunderstandings and mistakes The lack of a universally accepted list
of "tax havens" simply reflects the fact that the term does not have a
universally accepted definition. That lack of consensus results from
the fact that the different problems presented by so-called tax havens
often involve different groups of countries. For example, the list of
countries that will not agree to exchange tax information is not co-
extensive with the list of countries that do not impose an income tax.
Even though coming up with a list of tax haven countries has
significant appeal, any list of counties is likely to be under-
inclusive as well as over-inclusive, depending on the problem meant to
be addressed. Moreover, because any such list is likely to be regarded
as a blacklist and may be used as the basis for the imposition of
sanctions or other negative measures, such a list may inappropriately
negatively affect our economic and other relations with listed
countries.
Sincerely,
Signed by:
Michael Mundaca:
Deputy Assistant Secretary (International Tax Affairs):
[End of section]
Appendix V: Comments from the Internal Revenue Service:
Department Of The Treasury:
Commissioner:
Internal Revenue Service:
Washington, D.C. 20224:
December 11, 2008:
Mr. James R. White:
Director, Tax Issues
U.S. Government Accountability Office:
441 G Street, N.W.
Washington, DC 20548:
Dear Mr. White:
Thank you for providing your draft report, International Taxation:
Large U.S. Corporations and Federal Contractors with Subsidiaries
Listed as Tax Havens or Financial Privacy Jurisdictions (GAO-09-157).
The issues involved in the cross-border arena, including those
involving large U.S. corporations and their foreign subsidiaries, am
some of the most complex that the Service confronts. I have made
international issues like these a top priority for the IRS, in addition
to our continued efforts combating offshore tax evasion.
Because the landscape is complex, I welcome the support provided by
independent research and analysis that complements our own initiatives
in this area. Accordingly, I very much appreciate GAO's work on this
report and on this topic more generally.
If the IRS can provide any additional support to your efforts, please
contact Barry B. Shott, Deputy Commissioner (International), Large and
Mid-Size Business Division at 202-435-5000.
Sincerely,
Signed by: Douglas H. Shulman:
[End of section]
Appendix VI: GAO Contact and Staff Acknowledgments:
GAO Contact:
James R. White, (202) 512-9110 or whitej@gao.gov:
Acknowledgments:
In addition to the contact named above, Jonda Van Pelt, Assistant
Director; Joanna Berry; Michele Fejfar; Julia Kennon; Audrey Ruge;
Shellee Soliday; A. J. Stephens; and Megan Sullivan made key
contributions to this report.
[End of section]
Footnotes:
[1] Transfer prices are the prices related companies, such as parents
and subsidiaries, charge on intercompany transactions. These prices
affect the distribution of profits between the two companies.
[2] See Department of the Treasury, Report to the Congress on Earnings
Stripping, Transfer Pricing, and U.S. Income Tax Treaties (November
2007).
[3] Income shifting is transferring gross income from one taxpayer to
another taxpayer in a lower tax bracket or jurisdiction, thereby
reducing the overall liability of the original taxpayer.
[4] GAO, U.S. Multinational Corporations: Effective Tax Rates Are
Correlated with Where Income Is Reported, [hyperlink,
http://www.gao.gov/products/GAO-08-950] (Washington, D.C.: Aug. 12,
2008), which includes information for 17 foreign locations. For a GAO
review of the business reasons for establishing a business in a
specific jurisdiction, see GAO, Cayman Islands: Business and Tax
Advantages Attract U.S. Persons and Enforcement Challenges Exist,
[hyperlink, http://www.gao.gov/products/GAO-08-778] (Washington, D.C.:
July 24, 2008).
[5] GAO, International Taxation: Information on Federal Contractors
With Offshore Subsidiaries, [hyperlink,
http://www.gao.gov/products/GAO-04-293] (Washington, D.C.: Feb. 2,
2004).
[6] These characteristics include no or nominal taxes; lack of
effective exchange of tax information with foreign tax authorities;
lack of transparency in the operation of legislative, legal, or
administrative provisions; no requirement for a substantive local
presence; or self-promotion as an offshore financial center.
[7] These sources describe offshore financial centers as jurisdictions
that have a high level of nonresident financial activity and that may
have low or no taxes, light and flexible regulation, and a high level
of client confidentially, and describe financial privacy jurisdictions
as jurisdictions that have strict bank secrecy laws that persons can
use to shield their wealth from taxation in their home countries.
[8] OECD removes the Marshall Islands from its List of Unco-operative
Tax Havens, August 7, 2007, which includes a link to 35 Jurisdictions
Committed to Improving Transparency and Establishing Effective Exchange
of Information in Tax Matters.
[9] Dhammika Dharmapala and James R. Hines, Jr., Which Countries Become
Tax Havens? (National Bureau of Economic Research, Cambridge, Mass.:
December 2006).
[10] In the Matter of Tax Liabilities: of John Does, et al., No. 5:05-
cv-04167-JW (N.D. Cal. 2006).
[11] The court did not address whether these jurisdictions were in fact
tax havens in its ruling.
[12] We used the 2008 Fortune 500 list, which is based on revenues for
2007. The revenues were for the corporations' fiscal years, which ended
on or before January 31, 2008.
[13] USASpending.gov is a government Web site available to the public
that provides information about federal contracts. It utilizes data
from FPDS-NG and aggregates subsidiaries and divisions by parent
company using information provided by Dun and Bradstreet. We used
fiscal year 2007 contract obligations.
[14] We used information filed with the SEC to determine where
subsidiaries were located. The SEC only requires public corporations to
report significant subsidiaries. They may omit information on
subsidiaries that, when considered in the aggregate, would not
constitute significant subsidiaries, and on consolidated wholly owned
multiple subsidiaries carrying on the same line of business (such as
chain stores). Therefore, these corporations could have additional
subsidiaries not considered significant in jurisdictions listed as tax
havens or financial privacy jurisdictions. For more information about
the definition of significant subsidiaries, see app. I.
[15] GAO, International Taxation: Information on Federal Contractors
With Offshore Subsidiaries, [hyperlink,
http://www.gao.gov/products/GAO-04-293] (Washington, D.C.: Feb. 2,
2004).
[16] OECD is a forum where the governments of 30 market democracies
work together to address economic, social, and governance challenges of
globalization.
[17] The FSF was convened in April 1999 at the initiative of the G7
Finance Ministers and Central Bank Governors in order to promote
international financial stability, improve the functioning of financial
markets, and reduce the tendency for financial shocks to propagate from
country to country, thus destabilizing the world economy.
[18] Offshore financial centers 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.
[19] Financial privacy jurisdictions are generally described as
jurisdictions that have strict bank secrecy laws that persons can use
to shield their wealth from taxation in their home countries.
[20] In addition, the IMF had a list of jurisdictions that were
offshore financial centers. This list was based in part on work done by
the FSF. However, IMF is no longer maintaining a list of offshore
financial centers because it believes globalization is blurring the
distinction between offshore financial centers and other financially
active jurisdictions and there are no agreed-upon objective criteria
for defining offshore financial centers.
[21] OECD removes the Marshall Islands from its List of Unco-operative
Tax Havens, August 7, 2007, which includes a link to 35 Jurisdictions
Committed to Improving Transparency and Establishing Effective Exchange
of Information in Tax Matters.
[22] Dhammika Dharmapala and James R. Hines, Jr., Which Countries
Become Tax Havens? (National Bureau of Economic Research, Cambridge,
Mass.: December 2006).
[23] James R. Hines, Jr. and Eric M. Rice, "Fiscal Paradise: Foreign
Tax Havens and American Business," The Quarterly Journal of Economics,
vol. 109, no. 1 (1994): 149-182.
[24] A John Doe summons is a third-party summons that does not identify
the person with respect to whose tax liability the summons is issued
and may be served only after a court proceeding. A third-party summons
is a summons requesting information on a person or persons other than
the recipient of the summons. To obtain a John Doe summons, the United
States must establish that (1) the summons relates to the investigation
of a particular person or ascertainable group or class of persons whose
identity is unknown, (2) there is a reasonable basis for believing that
such person or group or class of persons may fail or may have failed to
comply with any provision of any internal revenue law, and (3) the
information sought to be obtained from the examination of the records
or testimony and the identity of the John Doe(s) is not readily
available from other sources. 26 U.S.C. § 7609(f).
[25] The court did not address whether these jurisdictions were in fact
tax havens in its ruling.
[26] According to an IRS Office of Research official, the office used a
list of tax havens in a research project. The list was developed many
years ago and does not include any jurisdictions that are not included
in the John Doe summons.
[27] OECD does not systematically review this list to determine if
jurisdictions should be removed from it.
[28] Dharmapala and Hines, Which Countries Become Tax Havens? NBER,
founded in 1920, is a private, nonprofit, nonpartisan research
organization dedicated to promoting a greater understanding of how the
economy works. NBER is committed to undertaking and disseminating
unbiased economic research among public policymakers, business
professionals, and the academic community and is the nation's leading
nonprofit economic research organization.
[29] Hines and Rice, "Fiscal Paradise: Foreign Tax Havens and American
Business." The Quarterly Journal of Economics is the oldest
professional journal of economics in the English language. Edited at
Harvard University's Department of Economics, it covers all aspects of
the field--from the journal's traditional emphasis on microtheory to
both empirical and theoretical macroeconomics.
[30] After deleting the Channel Islands from the list of 39 tax havens
and adding Jersey and Guernsey, the resulting total is 40.
[31] Andre Beauchamp, Guide Mondial des Paradis Fiscaux (Paris:
Editions Grasset & Fasqualle, 1983).
[32] The Economist Intelligence Unit is a global research and advisory
firm whose mission is to provide executives with authoritative analysis
and forecasts to make informed global decisions.
[33] Caroline Doggart, Tax Havens and Their Uses (London: Economist
Intelligence Unit, 1983).
[34] In the Matter of the Tax Liabilities of John Does, No. 5:05-cv-
04167-PVT (N.D. Cal. 2005).
[35] In the Matter of Tax Liabilities of John Does, et al., No. 5:05-
cv-04167-JW (N.D. Cal. 2006).
[36] A third-party summons is a summons requesting information on a
person or persons other than the recipient of the summons.
[37] To obtain a John Doe summons, IRS must establish that (1) the
summons relates to the investigation of a particular person or
ascertainable group or class of persons whose identity is unknown, (2)
there is a reasonable basis for believing that such person or group or
class of persons may fail or may have failed to comply with any
provision of any internal revenue law, and (3) the information sought
to be obtained from the examination of the records or testimony and the
identity of the John Doe(s) is not readily available from other
sources. 26 U.S.C. § 7609(f).
[38] Declaration of Barbara Kallenberg, In the Matter of the Tax
Liabilities of John Does, No. 5:05-cv-04167-PVT (N.D. Cal. 2005).
[39] Id. at 4-5.
[40] Id. at 48.
[41] Id. at 48-49.
[42] We used the 2008 Fortune 500 list, which is based on revenues for
2007. The revenues were for the corporations' fiscal years that ended
on or before January 31, 2008.
[43] USASpending.gov is a government Web site available to the public
that provides information about federal contracts.
[44] Subsidiaries are owned by corporations that may or may not be
publicly traded and joint ventures are owned by two or more
corporations that may or may not be publicly traded.
[45] Form 10-K is used for the annual reports or transition reports
that corporations file with the SEC according to the Securities
Exchange Act of 1934. 15 U.S.C. §§ 78m, 78o(d); 17 C.F.R. § 249.310.
[46] In Exhibit 21, public corporations are required to list their
subsidiaries and the names under which they do business and the state
or jurisdiction of incorporation or organization.
[47] In this case, the SEC defines such income as income from
continuing operations before income taxes, extraordinary items, and the
cumulative effect of a change in accounting principle.
[End of section]
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