A leak of searchable 11.5 million files, that’s 2.6 terabytes of data, from the embattled offshore services provider Mossack Fonseca. Every email, client note, asset and income statement, instruction, communication, .. since 1977! 2.6 terabytes of data, 11.5 million files, is a lot of files and scanned documents to comb through, so this leak is potentially, and probably, more significant than the 2014 ICIJ reported on leak or even the HSBC and UBS’ leaks.
The leaked data covers nearly 40 years, from 1977 through the end of 2015. ICIJ states that “It allows a never-before-seen view inside the offshore world — providing a day-to-day, decade-by-decade look at how dark money flows through the global financial system, breeding crime and stripping national treasuries of tax revenues.”
The law firm’s leaked internal files contain information on 214,488 offshore entities connected to people in more than 200 countries and territories. ICIJ will release the full list of companies and people linked to them in early May.
The data includes emails, financial spreadsheets, passports and corporate records revealing the secret owners of bank accounts and companies in 21 offshore jurisdictions, from Nevada to Singapore to the British Virgin Islands.
The ICIJ investigative reporters have been searching, extracting, then compiling lists of names and hidden dollars, reported on the ICIJ website here.
“When the complete list of 14,000 persons and each’s connections to offshore assets is published in early May by ICIJ, expect a free for all by the criminal investigative departments of the revenue authorities from the 200 countries uncovered in the files,” said Prof. William Byrnes of Texas A&M University’s School of Law. “This is the fifth major, game-changing, leak of offshore records, including Portcullis Trust (Singapore), HSBC, UBS, and LuxLeaks.”
“When all the leaked data is combined with all the thousands of taxpayer and offshore advisor files gleaned from offshore voluntary compliance and non-prosecution programs, then crunched with AI (artificial intelligence, or neural network) programs that “connects the dots”, many additional politicians and business leaders are going to be exposed to criminal and civil tax and corruption investigations.” continued William Byrnes. “I think many have been trying to run out the clock by suppressing this information. For some countries that strategy may work, but others countries will experience televised perp walks and political backlash.”
Professor William Byrnes added, “I expect to see investigations and prosecutions of attorneys and staff of Mossack Fonseca, and eventual extradition. Perhaps the firm will enter into nonprosecution agreements with governments, pay a fine, like the Swiss banks and several Big 4 accomplished, and turn over its remaining client files. It may be an end to the firm, but when its partners and staff are faced with a choice of either US and other countries long term prison sentences or providing evidence against clients, the clients are going to be ‘thrown under the bus’.”
**download here for free Prof. William Byrnes 118 page in-depth analysis of tax information exchange, FATCA and CRS ** “In the field of international tax, Prof. William Byrnes is among LexisNexis’s best-selling authors and a leading authority in the fields of anti-money laundering and FATCA compliance.” Ray Camiscioli, Esq., Director, Product Strategy & Development for Tax, Accounting and Estates/Elder Law, LexisNexis, Inc.
Professor William Byrnes pivoted in the discussion, “The US has a highly successful international financial service industry that is important to the US economy, exemplified by, firstly, the international financial centres such as Miami and New York) of over a half trillion dollars of foreign deposits of high net wealth individuals whom many experts allege are not tax and exchange control compliant in their home countries; secondly, over 900,000 Delaware companies is the second to Hong Kong, and ahead of British Virgin Islands (BVI is actually third in the world); and thirdly, the US territories’ offshore regimes, reducing the effective US corporate and income tax rates below 3.5 percent.”
“In 2011, 133,297 businesses incorporated in Delaware. Delaware has more corporate entities than people — 945,326 to 897,934,” he continued. “These absentee corporate residents account for a quarter of Delaware’s total budget, roughly $860 million in taxes and fees in 2011. Moreover, the economic spill-over impact for Delaware includes substantial employment and professional fees to Delaware business participating in the incorporation and advisory industry. Delaware is just behind China’s Hong Kong in number of annual incorporations and overall incorporations, and well ahead of the UK’s Virgin Islands (British) both in terms of offshore business and the dollars earned from that offshore business. Thus, I wonder how many of these Delaware companies, and Delaware corporate service providers, will be exposed once the data is disclosed by ICIJ in May?”
 “Storm Survivors”, Special Report: Offshore Finance, The Economist, 16 Feb 2013.
 See William H Byrnes and Dr. Robert J Munro, Tax Havens of the World, US Virgin Islands chapter, LexisNexis. See also Prof. William Byrnes’ 118 page in-depth analysis of tax information exchange, FATCA and CRS.
 See Wayne, Leslie, How Delaware Thrives as a Corporate Tax Haven, New York Times (June 30, 2012).