5 Storey Building in Cayman is home to over 18,500 Firms

A report to be published this morning by the Senate Finance Committee's Government Accountability Office (GAO) will disclose that the number of companies that list their address in a five-story building in the Cayman Islands nearly doubled to more than 18,500 during the past four years, according to a source who has seen the report.

The building is called "Ugland House" and as of March 2008 was home to 18,857 business tenants. That was up from 12,748 reported tenants in August of 2004 - an increase of four tenants a day. Sen. Max Baucus, D-Mont., who is chairing a Thursday hearing of the Senate Finance Committee on the issue, called the findings "hugely troubling." "When you see a huge spike in tenancy in a place like the Ugland House, where no one's really sure what's going on, decent oversight demands that you ask more questions," Baucus said. "If we strengthen transparency for U.S. holdings in places like the Caymans, it will be a lot easier for the IRS to tell who's not playing by the rules."

The GAO report is the culmination of a yearlong inquiry conducted at the behest of the Senate Finance Committee and comes on the heels of another Senate investigation that said the use of tax havens has cost America an estimated $100 billion a year in lost revenue. Companies with addresses in Ugland House are clients of the law firm Maples & Calder, which is the building's sole tenant. Investigators from the General Accounting Office traveled to the Cayman Islands earlier this year and interviewed officials with the law firm. Maples and Calder told GAO that only around 5% of the entities it serves are wholly-U.S. owned.

The GAO also found that U.S. persons reporting to the U.S. Treasury that they control Caymans bank accounts jumped to 7,937 last year, up from 2,677 in 2002. In addition, 732 companies that trade on the U.S. stock exchange are incorporated in the Caymans, GAO said. More than a third of the entities that reside at Ugland House - about 38% - are hedge fund or private equity-related. Caymans-based hedge funds offer U.S. tax-exempt entities like pension funds and foundations the ability to legally invest in the high-return vehicles without paying a U.S. tax that applies to leveraged investments. They also serve foreign investors who prefer not to invest in U.S.-domiciled funds for tax, regulatory or political reasons. Most hedge funds that operate in the Caymans are part of a "master feeder structure" that includes a mirror U.S. fund. Fund managers are responsible for ensuring that U.S. investors only invest in the U.S. feeder fund.

Another 24% of firms registered at Ugland House are related to structured finance - for example, leasing corporations set up to finance commercial aircraft. The remainder, about 38%, are corporate entities like holding companies and wholly-owned subsidiaries. Some of these are legal entities set up by U.S. firms to facilitate doing business overseas. But others are created for the purpose of tax fraud or evasion, GAO said. GAO identified 21 civil and criminal cases brought by U.S. authorities against Caymans entities.