The U.S. Senate Subcommittee on Investigations has an
interesting report showing some examples of how schemes involving offshore shell companies have been used to evade US taxes. It's from 2006.
Two weeks later, Mr. Greenstein sent Mr. Wilk an email suggesting that the considerations in
hiring a firm [a tax law firm to produce a written opinion to the effect that a proposed scheme would be legal] were not only who had the best credentials, but who would be most "aggressive":
"Had drinks last night with friends from Mayer Brown & Platt/ Akin Gump, Strauss & Howard/ Millbank, Tweed, Hadley & McCoy/ Battle Fowler. Battle Fowler does a lot of real estate and some very aggressive basis savings transactions. My friend thinks they would have clients with high basis low FMV[fair market value] assets (the bad assets) and clients who would like our trade because they have low basis high FMV real estate. He also thinks they would be willing to opine. My friend also told me that Shearman and Sterling had been very aggressive on 704(c) transactions prior to the re-write of that section and would probably still retain an aggressive stance. Spoke with Chris ... about Mayer Brown & Pratt. He will check but believes UBS would take their opinion and told me that there had been an occasion when MBP opined for the Bank when Cravath would not."