United States v. Greenfield

CALABRESI, Circuit Judge:

A remarkable amount of American wealth is held offshore, often in an effort to evade taxation. One recent study estimated that $1.2 trillion — some four percent of this nation’s wealth — is held offshore and that this results in an annual loss in tax revenue of $35 billion. Gabriel Zucman, The Hidden Wealth of Nations: The Scourge of Tax Havens 53 (Teresa Lavender Fagan trans., 2015). Such lost income diminishes the Treasury and exacerbates inequality since, generally, only the wealthiest of individuals can take advantage of foreign tax havens. Id. Recognizing this,…