title: Carl Bernstein

text: On a Saturday in June 1972, Bernstein was assigned, along with Bob Woodward, to cover a break-in at the Watergate office complex that had occurred earlier the same morning. Five burglars had been caught red-handed in the complex, where the Democratic National Committee had its headquarters; one of them turned out to be an ex-CIA agent who did security work for the Republicans. In the series of stories that followed, Bernstein and Woodward eventually connected the burglars to a massive slush fund and a corrupt attorney general. Bernstein was the first to suspect that President Nixon was involved, and he found a laundered check that linked Nixon to the burglary. Bernstein and Woodward's discoveries led to further investigations of Nixon, and on August 9, 1974, amid hearings by the House Judiciary Committee, Nixon resigned in order to avoid facing impeachment.


title: Carl Bernstein

text: In 1974, two years after the Watergate burglary and two months before Nixon resigned, Bernstein and Woodward released the book "All the President's Men". The book drew upon the notes and research accumulated while writing articles about the scandal for the "Post" and "remained on best-seller lists for six months". In 1975, it was turned into a movie starring Dustin Hoffman as Bernstein and Robert Redford as Woodward which later went on to be nominated in multiple Oscar (including Best Picture nomination), Golden Globe and BAFTA categories. A second book, "The Final Days", was published by Bernstein and Woodward in 1976 as a follow-up chronicling Nixon's last days in office.


title: Carl Bernstein

text: Bernstein left the "Post" in 1977 and expanded into other areas due to his reputation from the Watergate reporting. He joined broadcast news in a high growth period. He worked at ABC, CNN, and CBS as a political commentator, and was a spokesman in various television commercials. He began investigating the secret cooperation between the CIA and American media during the Cold War. He spent a year in his research, which was published as a 25,000-word article in "Rolling Stone" magazine.


title: Carl Bernstein

text: He then began working for ABC News. Between 1980 and 1984, Bernstein was the network's Washington Bureau Chief and then a senior correspondent. In 1982, for ABC's "Nightline", Bernstein was the first to report during the Israeli invasion of Lebanon that Ariel Sharon had "deceived the cabinet about the real intention of the operation—to drive the Palestinians out of Lebanon, not (as he had claimed) to merely establish a 25-kilometer security zone north from the border".


title: Carl Bernstein

text: Two years after leaving ABC News, Bernstein released the book "Loyalties: A Son's Memoir", in which he revealed that his parents had been members of the Communist Party of America. The assertion shocked some because even J. Edgar Hoover had tried and been unable to prove that Bernstein's parents had been party members.


title: Carl Bernstein

text: In 1992, also for "Time", Bernstein wrote a cover story publicizing the alliance between Pope John Paul II and President Ronald Reagan. Later, along with Vatican expert Marco Politi, he published a papal biography entitled "His Holiness". Bernstein wrote in the 1996 book that the Pope's role in supporting Solidarity in his native Poland, and his geopolitical dexterity combined with enormous spiritual influence, was a principal factor in the downfall of communism in Europe.


title: Carl Bernstein

text: In 1992, Bernstein wrote a cover story for "The New Republic" magazine indicting modern journalism for its sensationalism and celebration of gossip over real news. The article was entitled "The Idiot Culture".


title: Carl Bernstein

text: Bernstein's biography of Hillary Rodham Clinton, "A Woman In Charge: The Life of Hillary Rodham Clinton", was published by Alfred A. Knopf on June 5, 2007. Knopf had a first printing of 275,000 copies. It appeared on "The New York Times" Best Seller list for three weeks. A CBS News end-of-year survey of publishing "hits and misses" included "A Woman in Charge" in the "miss" category and implied that its total sales were somewhere in the range of perhaps 55,000–65,000 copies.


title: Carl Bernstein

text: Bernstein is a frequent guest and analyst on television news programs, and in 2011 wrote articles for "Newsweek"/"The Daily Beast", comparing Rupert Murdoch's "News of the World" phone-hacking scandal to Watergate.


title: Carl Bernstein

text: In 2012, Carl Bernstein spoke at a rally of People's Mujahedin of Iran, an opposition Iranian organization that had previously been listed as a Foreign Terrorist Organization by the United States, reportedly receiving a payment for his speech.


title: Carl Bernstein

text: Bernstein has been married three times, first to a fellow reporter at "The Washington Post", Carol Honsa; then to writer and director Nora Ephron from 1976 to 1980; and since 2003 to the former model Christine Kuehbeck.


title: Carl Bernstein

text: During his marriage to Ephron, Bernstein met Margaret Jay, daughter of British Prime Minister James Callaghan and wife of Peter Jay, then UK ambassador to the United States. They had a much-publicized extramarital relationship in 1979. Margaret later became a government minister in her own right. Bernstein and second wife Ephron already had an infant son, Jacob, and she was pregnant with their second son, Max, in 1979 when she learned of her husband's affair with Jay. Ephron delivered Max prematurely after finding out. Ephron was inspired by the events to write the 1983 novel "Heartburn", which was made into a 1986 film starring Jack Nicholson and Meryl Streep.


title: Carl Bernstein

text: While single, in the 1980s, Bernstein became known for dating Bianca Jagger, Martha Stewart, and Elizabeth Taylor, among others.


title: Carl Bernstein

text: Bernstein was portrayed by Dustin Hoffman in the film version of "All the President's Men", and by Bruce McCulloch in the 1999 comedy film "Dick".


title: Carl Bernstein

text: Although they worked together to report the Watergate scandal to the world, Bernstein and Woodward had very different personalities. Raised in a traditional Republican household, Woodward was very well-educated and has been described as gentle. After graduating from Yale University, he joined "The Washington Post"; nine months later, he was assigned the Watergate break-in story. On the other hand, Bernstein was born to a Communist Jewish family. He was rebellious, which led to him dropping out of college. He was ten months further along in his career than Woodward when the scandal broke out.


title: Carl Bernstein

text: They were also different in work styles. Woodward's strength was in investigation, so he focused on investigating the Watergate scandal. He met his Deep Throat source secretly to get as much information as possible. His writing was serious and matter-of-fact. However, Bernstein was the first of the pair to think that the Watergate case could be related to President Richard Nixon. Compared to Woodward, Bernstein was a strong writer, and therefore wrote articles based on Woodward's information from Deep Throat. Due to their different styles, other journalists described them as a perfect team. Alicia Shepard said, "Carl was the big thinker, and Woodward was the one that [made] sure it got done ... [T]hey knew that each of them had strengths that the other didn't, and they relied on one another."


title: Rhonda Ross Kendrick

text: Rhonda Ross Kendrick (born Rhonda Suzanne Silberstein; August 14, 1971) is an American singer and actress. She is the daughter of singer and actress Diana Ross. She was born in Los Angeles and raised by Ross and her first husband, Robert Ellis Silberstein. Her biological father is Motown Records founder Berry Gordy, but she was raised by her former stepfather Silberstein, a man she remains close with today, and he is considered her legal father.


title: Rhonda Ross Kendrick

text: At the time of Rhonda's birth, Diana Ross was married to her first husband, Robert Ellis Silberstein. Ross, Gordy, and Silberstein all knew of Rhonda's parentage. She was publicly presented as the daughter of Ross and Silberstein, and he raised her. When she was 13, she was told Gordy was her biological father. Ross Kendrick has said that the revelation came as a relief. She was beginning to notice physical differences between herself and her younger sisters. The revelation gave her an answer to the situation. Rhonda Ross Kendrick is the eldest of Diana Ross' five children and the seventh of Berry Gordy's eight biological children. She is a graduate of Brown University.


title: Rhonda Ross Kendrick

text: Ross Kendrick's most famous acting credit is Toni Burrell on "Another World". She played the role from 1997 to 1999 and was nominated for a Daytime Emmy Award in 1998. She also appeared in the movie "The Personals" (1999) with Malik Yoba as well as "The Temptations" miniseries with her relative Bianca Lawson. In 2004, she released her debut live album "Rhonda Ross Live Featuring Rodney Kendrick".


title: Rhonda Ross Kendrick

text: After working for two years as an agent with the firm Citi Habitats, she founded Ross Realty International, a real-estate brokerage firm in New York City in 2008.


title: Rhonda Ross Kendrick

text: In 2013, she joined her mother (Diana Ross) on the In the Name of Love Tour as the opening act for her concerts. In July 2016, she released her first studio album "In Case You Didn't Know". The album spawned the singles "Summer Day" and "In Case You Didn't Know".


title: Rhonda Ross Kendrick

text: On September 13, 1996, she married jazz musician Rodney Kendrick. On August 7, 2009, she gave birth to their son.


title: Carlos Mencia

text: Ned Arnel "Carlos" Mencía (born October 22, 1967) is a Honduran-American comedian, writer, and actor. His style of comedy is often political and involves issues of race relations, Latin American culture, criminal justice, and social class. He is best known as the host of the Comedy Central show "Mind of Mencia" (2005–2008). Around the time of the show's cancellation, several comedians accused Mencía of plagiarism and stealing jokes.


title: Carlos Mencia

text: Ned Arnel Mencía was born in San Pedro Sula on October 22, 1967, the son of Mexican mother Magdelena Mencía and Honduran father Roberto Holness. He has 16 older siblings and one younger sibling. At the time of his birth, his mother was engaged in a domestic dispute with his father, and she subsequently refused to give Mencía his biological father's surname. Out of respect for his father, he later began using the Holness surname anyway, and did so until the age of 18. He moved to the U.S. as a child and was raised Catholic in East Los Angeles by his aunt Consuelo and uncle Pablo Mencía. By his own admission, staying out of trouble was difficult while growing up, but his family helped him excel in school and stay out of gangs. He dealt drugs and robbed a house when he was 19 years old. He attended Garfield High School in Los Angeles County, and later majored in electrical engineering at California State University, Los Angeles; however, he dropped out to pursue a career in comedy after a successful performance at an open mic night at The Laugh Factory. In 1988, at the suggestion of Comedy Store owner Mitzi Shore, he began using the first name "Carlos" to appeal to Mexican audiences.


title: Carlos Mencia

text: Mencia performed at venerated LA stand-up venues such as The Comedy Store and The L.A. Cabaret. His success in these venues led to appearances on "The Arsenio Hall Show" and "Buscando Estrellas," where he attained the title "International Comedy Grand Champion." Then, in 1994, Mencia was chosen to host HBO's latino comedy showcase "Loco Slam."


title: Carlos Mencia

text: Mencia followed up "Loco Slam" by hosting "Funny is Funny!" on Galavision in 1998. He would continue to do stand-up, including a successful tour in 2001 with Freddy Soto and Pablo Francisco, "The Three Amigos." Mencia also did two half-hour specials on HBO, the second of which won him a CableACE Award for "Best Stand-Up Comedy Special." After the release of his first comedy album by Warner Records, "Take A Joke America," Mencia performed his break-out performance on "Comedy Central Presents" in 2002.


title: Carlos Mencia

text: By the time his career began to take off in the early 2000s, Mencia was also working as an actor doing guest appearances in the television shows "Moesha" and "The Shield," and starring in the film "Outta Time" and the animated show "The Proud Family."


title: Carlos Mencia

text: In 2002, he performed on "Comedy Central Presents". In March 2005, Comedy Central announced Mencia's own half-hour comedy show, "Mind of Mencia". The show mixed Mencia's stand up comedy with sketch comedy, much like Dave Chappelle's "Chappelle's Show". The show achieved moderate success in its first season and was brought back for a second season in the spring of 2006, becoming Comedy Central's second highest-rated program behind "South Park". It was brought back for a third season that summer before being cancelled in 2008. "Mind of Mencia" was produced by Nedlos, a portmanteau of Mencia's birth name and the name he took prior to naturalizing in the US.


title: Carlos Mencia

text: Mencia was sometimes a guest on the Opie and Anthony radio show on XM Satellite Radio and CBS Radio. He took part in the first Opie and Anthony's Traveling Virus Comedy Tour in 2006.


title: Carlos Mencia

text: Mencia starred in a Super Bowl XLI commercial for Bud Light. In November 2009, Mencia began appearing in commercials for a weight-loss product called Belly Burner.


title: Carlos Mencia

text: Mencia went on a 2011 stand-up comedy tour, including dates at the Improv in Schaumburg, Illinois, on June 24 and 25, and ending in Las Vegas at Treasure Island on September 16, 2011.


title: Carlos Mencia

text: Mencia was a co-founder of the restaurant chain Maggie Rita's, and a co-owner of several locations. By January 2013, Mencia's restaurants had closed amid poor reviews, though one franchised location continued to license the name.


title: Carlos Mencia

text: In 2006, "Maxim" named Mencia one of the worst comedians of all time. Mike Byoff of Gawker said of Mencia, "Not only does he steal jokes from classic comedians but he's needlessly racist and had no sense of comedic timing whatsoever."


title: Carlos Mencia

text: A 2010 article in "The Wall Street Journal" noted that Mencia, Dane Cook, and Jay Leno were three of the most popular stand-ups that were hated by fellow comedians.


title: Carlos Mencia

text: In 2005, comedian Joe Rogan wrote a post on his website publicly accusing Mencia of being a plagiarist, alleging that Mencia stole jokes from a number of comedians. On February 10, 2007, Rogan confronted Mencia on stage at the Comedy Store on Sunset Boulevard and accused him of plagiarism. Rogan posted a video of the altercation, along with audio and video clips from other comedians including George Lopez, Bob Levy, Bobby Lee, and Ari Shaffir, among others. Rogan has also posted audio and video clips of Mencia's interviews and joke routines comparing Mencia's routines to those of other comedians on his blog.


title: Carlos Mencia

text: Comedian George Lopez also accused Mencia of plagiarizing his material. In an interview on "The Howard Stern Show", Lopez accused Mencia of plagiarizing 13 minutes of his material in Mencia's HBO special. He also claimed he had a physical altercation with Mencia over the alleged plagiarism. The only joke that Lopez has publicly specified was stolen and used on Mencia's HBO special was a Taco Bell joke. Comedian Ted Sarnowski countered this claim, stating that the joke he performed on radio in 1988 was later taken and used without permission by Lopez, the radio station's resident comic. Sarnowski claims to have given Mencia permission to use the joke.


title: Carlos Mencia

text: Mencia has also been accused of stealing a routine from Bill Cosby. In his special, "No Strings Attached", Mencia performs a bit about a father who spends years training his son for a career as a football player, only to see the son say "I love you, Mom!" at his moment of televised victory. Cosby performed a similar bit in his concert film "" and wrote briefly on the subject in his book "Fatherhood". Mencia told the "Los Angeles Times" that he had never seen the film but regretted the similarities between his and Cosby's jokes.


title: Carlos Mencia

text: Mencia addressed the issue of plagiarism in two hour-long interviews with comic Marc Maron on his podcast, "WTF with Marc Maron", in May 2010. In 2011, Mencia stated in an interview that he had been in therapy due to accusations of plagiarism.


title: Carlos Mencia

text: In February 2009, Mencia was dropped from the Krewe of Orpheus' celebrity lineup for New Orleans Mardi Gras, citing inappropriate comments he made in the aftermath of Hurricane Katrina. Mencia remarked during his stand-up: "I'm glad Hurricane Katrina happened. It taught us an important lesson: Black people can't swim."


title: Carlos Mencia

text: Mencia married his wife, Amy, in 2003. They reside in Los Angeles and have one son named Lucas Pablo Mencia.


title: Carlos Mencia

text: Mencia has also appeared on "Comic Relief", and hosted "Loco Slam" in 1994, "Latino Laugh Festival" in 1997, "Funny is Funny!" in 1998, and "Uncensored Comedy: That's Not Funny" in 2003.


title: Arby's

text: Arby's is an American fast food sandwich restaurant chain with more than 3,300 restaurants system wide and third in terms of revenue. In October 2017, "Food & Wine" called Arby's "America's second largest sandwich chain (after Subway)".


title: Arby's

text: Arby's is the flagship property of Inspire Brands, the renamed Arby's Restaurant Group, Inc. (ARG). ARG was renamed as the company took over ownership of Buffalo Wild Wings on February 5, 2018.


title: Arby's

text: Roark Capital Group acquired 81.5% of Arby's Restaurant Group in July 2011 and is now a majority-owner of Inspire Brands. The Wendy's Company held a minority stake of 18.5% in Arby's after the acquisition by Roark Capital; that share was reduced to 12.3% upon the purchase of Buffalo Wild Wings, and was sold back to Inspire Brands on August 16, 2018, for 450 million dollars, a 38 percent premium.


title: Arby's

text: In addition to its classic Roast Beef and Beef 'n Cheddar sandwiches, Arby's products also include a deli-style Market Fresh line of sandwiches, Greek gyros, Curly Fries and Jamocha Shakes. Its headquarters are in Sandy Springs, Georgia, a suburb of Atlanta which uses Atlanta mailing addresses.


title: Arby's

text: In 2019, there were 3,472 restaurants. There are locations in five countries outside the United States: Canada, Mexico, Turkey, Egypt and South Korea.


title: Arby's

text: Arby's was founded in Boardman, Ohio, on July 23, 1964, by brothers Forrest (1922–2008) and Leroy Raffel, owners of a restaurant equipment business who thought there was a market opportunity for a fast food franchise based on a dish other than hamburgers. They wanted to call their restaurants "Big Tex", but that name was already used by an Akron business. Instead, they chose the name "Arby's," based on "R. B.", the initials of Raffel Brothers; although often mistaken for Roast Beef.


title: Arby's

text: The Raffel brothers opened the first new restaurant in Boardman, Ohio, just outside Youngstown, on July 23, 1964. They initially served only roast beef sandwiches, potato chips, and soft drinks. Hoping to attract a more upscale clientele, Arby's interior design was purposely more luxurious in appearance than the typical fast food sandwich stand of the day. Arby's offered their roast beef sandwiches for $.69 at a time when hamburger stands were charging $.15 for a hamburger. A year later, the first Arby's licensee opened a restaurant in Akron, Ohio. The famous Arby's "hat" was designed by the original sign makers, Peskin Sign Co.


title: Arby's

text: During the 1970s, the expansion of Arby's took place at a rate of 50 stores per year. During this time it created several menu items, including the Beef 'n Cheddar, Jamocha Shakes, chicken sandwiches, Curly Fries, and two signature sauces: Arby's Sauce and Horsey Sauce. Baked potatoes were added to the menu in 1985. Curly Fries were initially introduced as Curly-Q Fries in 1988. It became the first restaurant in the fast food industry to offer a complete "lite" menu in 1991 with several sandwiches and salads under 300 calories and 94 percent fat-free.


title: Arby's

text: The family-owned business tried converting into a public company in 1970 by offering the sale of stock, but the IPO never went through when the stock market subsequently fell. In 1976, the family sold the company to Royal Crown Cola Company for $18 million and Leroy Raffel remained as CEO until his retirement three years later.


title: Arby's

text: In 1984, Victor Posner obtained Arby's via a hostile takeover of its then parent Royal Crown through his DWG Corporation. Nine years later, with a new owner of DWG Corporation and a new name, Triarc Companies, Inc., a former PepsiCo executive, Don Pierce, was brought in to "resurrect" Arby's. With $100 million additional funding, Pierce moved to a new "Roast Town" concept, similar in format to Boston Market, in 1996. The Roast Town concept received poor marks in market tests and was quickly discontinued. Pierce and his team left the company and it sold all of its 354 company-owned locations to RTM Restaurant Group, an existing Arby's franchise, for $71 million. Another marketing concept that was tried was a dual-brand venture that was started in 1995 with ZuZu's Handmade Mexican Grill. The marketing venture was a failure resulting in lawsuits being filed by each company against the other.


title: Arby's

text: In 1992, Les Franchises P.R.A.G. Inc. opened the first Arby's franchise in the Canadian province of Quebec. It was also the 100th location to open in Canada and joins other locations that were then operating in the provinces of Ontario, Alberta, New Brunswick, Nova Scotia, Manitoba, British Columbia, and Saskatchewan. The Quebec location also sold the uniquely French-Canadian dish called poutine.


title: Arby's

text: In 2002, Arby's returned to operating restaurants by purchasing the second largest Arby's franchisee, Sybra Inc., with 293 locations out of bankruptcy outbidding RTM so as to prevent RTM from becoming too large. RTM was purchased by Arby's on July 25, 2005.


title: Arby's

text: In November 2002, Access Now filed a lawsuit against RTM, then a franchise of Triarc, that some 800 of their stores did not comply with the Americans with Disabilities Act of 1990 (ADA). The lawsuit had no liability damages except for lawyer fees. In August 2006, the court accepted the settlement between RTM and Access Now. The result was that every year, 100 of the RTM stores would be retrofitted to comply with the ADA. Accordingly, it was estimated that about $1.2 million would be spent to retrofit those stores each year.


title: Arby's

text: In 2008, Triarc purchased Wendy's, and changed its name to Wendy's/Arby's Group, to reflect their core businesses. In January 2011, it was announced that Wendy's/Arby's Group were looking into selling the Arby's side of the business to focus on the Wendy's brand. It was officially announced the companies would split on January 21, 2011. In 2009, the Wendy's/Arby's Group signed a franchise deal with the Al Jammaz Group of Saudi Arabia to open dual-branded Wendy's/Arby's through the Middle East with the first location opening in Dubai in the United Arab Emirates in May 2010. The Wendy's/Arby's Group also signed a similar franchise deal in June 2010 with Tab Gida Sanayi ve Ticaret to open dual-branded restaurants in Turkey. After the split, the former Wendy's/Arby's Group became The Wendy's Company.


title: Arby's

text: In 2010, Arby's opened a restaurant at Ft. Bliss, their first location at an American military base under a deal that the Wendy's/Arby's Group had signed with the Army and Air Force Exchange Service to open restaurants at bases both in the United States and overseas. Only American military personnel and some of their guests can patronize the Arby's locations situated on the military bases and operated by the Post Exchange.


title: Arby's

text: There were two different attempts to operate franchises in the United Kingdom. GSR Restaurant Group opened their first Arby's franchise location in London in 1992 followed by a second location the following year in Glasgow. These were also the first locations to open in Europe, but both were forced to close by 1994. In 2001, Barown Restaurants opened two Arby's franchise locations in Southampton, Hampshire, and Sutton, Surrey, but both were forced to close after operating for a few months.


title: Arby's

text: On June 13, 2011, Wendy's/Arby's Group Inc. announced that it would sell the majority of its Arby's chain to Roark Capital Group while maintaining an 18.5% stake in the company. At the time of the sale, Arby's was experiencing an operating loss for the year of $35 million with 350 Arby's franchisees more than 60 days late in royalty payments and 74 low performing franchised units and 96 company-owned units forced to close. Despite its cash flow problem, Arby's also reported that it had six months of sales growth at established stores in the United States which it had attributed to its new turnaround plan that it had recently launched. The new owners turned the company around by closing more underperforming locations, changing the company's marketing strategy, and by introducing new products on a regular basis. After four years, Arby's was able to issue $300 million in dividends, which resulted in Wendy's receiving $54.9 million for its minority stake with the remainder paid to Roark.


title: Arby's

text: In February 2017, Arby's reported that they were investigating a malware attack on its payment card system that had targeted thousands of customers' credit and debit cards. The malware was placed on point-of-sale systems inside Arby's corporate-owned restaurants, not its locations owned by franchisees, and was active between October 25, 2016, and January 19, 2017. Eight credit unions and banks from Alabama, Arkansas, Indiana, Louisiana, Michigan, Pennsylvania and Montana have filed suit since early February against Arby's concerning the data breach.


title: Arby's

text: In September 2017, Arby's returned to Kuwait for the first time in two decades by the opening of an Arby's franchise in Jabriya by Kharafi Global.


title: Arby's

text: In November 2017, Arby's announced it had negotiated a purchase for the restaurant chain Buffalo Wild Wings for $2.4 billion in cash. As part of this acquisition, the parent was renamed from Arby's Restaurant Group, Inc. to Inspire Brands.


title: Arby's

text: In October 2018, Arby's expanded into the North African country of Egypt by opening three restaurants in the capital city of Cairo with the help of local franchise partner Vantage Egypt Tourism and Entertainment.


title: Arby's

text: In addition to roast beef, deli style sandwiches, called "Market Fresh Sandwiches," are sold at Arby's. The original lineup of sandwiches included Roast Beef and Swiss, Roast Turkey and Swiss, Roast Ham and Swiss, and Roast Chicken Caesar. With the exception of the Chicken Caesar, all Market Fresh Sandwiches came with the standard toppings of spicy brown honey mustard, mayonnaise, red onion rings, green leaf lettuce, tomato slices and sliced Swiss cheese. Additions to the Market Fresh lineup included Roast Turkey Ranch and Bacon and the Ultimate BLT. Market Fresh Five-Star Club, served on Harvest White Bread, was introduced in 2003 for a limited time.


title: Arby's

text: In 2003, the line was again expanded to include other styles of specialty sandwiches that were served on baguettes that included the Italian Beef 'n Provolone, French Dip 'n Swiss, Philly Beef Supreme, and Pot Roast sandwiches.


title: Arby's

text: In early 2006, Arby's Restaurant Group signed a contract with Pepsi, making Pepsi the chain's exclusive soft drink provider. Franchises which had contracts with Coca-Cola switched to Pepsi-Cola when their contracts with Coca-Cola expired. The one exception was the Arby's located at Youngstown State University, because the university had its own separate contract with Coca-Cola for other university purposes, particularly the athletic department. This Arby's closed in mid-2012 when construction began to convert the location into a Wendy's. It was announced in August 2017, that Coca-Cola had won a contract to serve Coke products at all its restaurants, ending an almost 11-year association with Pepsi. The transition began in early 2018, and all Arby's locations were serving Coca-Cola beverages by June 19, 2018. Arby's promoted their announcement by breaking two Guinness World Records. The first record, "world's smallest advertisement", measured 38.3 microns by 19.2 microns on a sesame seed and was printed at Georgia Tech. The second record, "largest advertising poster", took up approximately 5 acres of land and was placed in Monowi, Nebraska, America's smallest town.


title: Arby's

text: Toasted Subs, sandwiches served on a toasted ciabatta roll, were first introduced in September 2007. The initial line-up included the French Dip & Swiss Toasted Sub, Philly Beef Toasted Sub, Classic Italian Toasted Sub, and Turkey Bacon Club. Three months later, the Toasted Subs product line was extended to include the Meatball Toasted Sub and the Chicken Parmesan Toasted Sub.


title: Arby's

text: In September 2014, Arby's introduced gyros to its menu for a limited time. Gyros were previously offered in 2006. They have since become a permanent menu fixture on the menu in April 2016.


title: Arby's

text: On an almost annual basis, Arby's had offered some sort of a flatbread melt sandwich for a limited time. In 2007 and again in 2008, it was the Philly Cheesesteak and the Fajita Beef. The Beef Fajita returned with the new Chicken Fajita in 2009. After a six-year hiatus, Steak Fajita Flatbreads were offered for a limited time in 2015. The following year, Steak Fajita returned in 2016 with Chicken Fajita along with a choice between a hot and mild sauce.


title: Arby's

text: In August 2015, Arby's introduced a series of five small sandwiches called Sliders starting at $1.29, with prices varied by location. These new menu items led to an increase in sales at many locations. This is not the first time Arby's tried to market miniature sandwiches. Two years earlier, Arby's tried to sell a similar product called the Mighty Minis that were sold in pairs. During the first month of national sales, the firm was able to sell 1 million or a ton of sliders. To encourage additional sales outside normal lunch and dinner meal hours, began to offer sliders and small size drinks and sides at the reduced price of $1 between the hours of 2 and 5 p.m. starting in October 2015. Due to Arby's great success in the increase of sales created by the introduction of this new product line, Nation's Restaurant News awarded Arby's its MenuMasters Award for 2016. The Turkey 'n Cheese was initially offered as a limited time menu item in December 2016 but was shown to be popular enough to be retained on the regular menu. A Pizza Slider was introduced as a limited time menu item in May 2017.


title: Arby's

text: In late August 2016, Arby's introduced four chicken sandwiches that used a buttermilk-based breaded breast filet.


title: Arby's

text: In October 2016, word leaked through social media that Arby's was about to test a venison sandwich, which Arby's confirmed, selecting 17 stores in Georgia, Michigan, Minnesota, Pennsylvania, Tennessee, and Wisconsin (all major deer hunting states) to offer it during a four-day test during those states' respective hunting seasons. Prior to the start of the promotion, "USA Today" published the locations of all 17 participating restaurants. Both due to curiosity and heavy demand from hunters, the sandwiches sold out in all markets on the first day of the test. Another "USA Today" article reported that the farm-raised venison was imported from New Zealand. In the following year, Arby's announced that the venison sandwich would return nationwide on October 21, 2017, also available in limited quantities.


title: Arby's

text: In September 2017, Arby's introduced the Chicken Pepperoni Parm sandwich, their version of a chicken parmigiana sandwich which also contains pepperoni slices.


title: Arby's

text: In October 2017, Arby's announced that three locations in Colorado, Montana, and Wyoming will offer an elk sandwich for a limited time. The farm-raised elk meat that was used to make the sandwiches was obtained from the same farm in New Zealand that provides the venison to Arby's since many states, such as Montana, prohibit the raising of game animals on commercial farms.


title: Arby's

text: The following October, Arby's once again offered a featured wild game sandwich in 16 of its restaurants. This time, it would be a duck breast sandwich topped with a cherry sauce and crispy onions.


title: Arby's

text: Some locations also serve breakfast, including at truck stop locations operated by Pilot Flying J and Love's Travel Stops and Country Stores that are typically operating 24 hours.


title: Arby's

text: Since 2014, Ving Rhames has been the narrator of Arby's commercials. The chain's current slogan is "Arby's, We Have The Meats!"


title: Particle physics

text: Particle physics or high energy physics is the study of fundamental particles and forces that constitute matter and radiation. The fundamental particles in the universe are classified in the Standard Model as fermions (matter particles) and bosons (force-carrying particles). There are three generations of fermions, but ordinary matter is made only from the first fermion generation. The first generation consists of up and down quarks which form protons and neutrons, and electrons and electron neutrinos. The three fundamental interactions known to be mediated by bosons are electromagnetism, the weak interaction, and the strong interaction.


title: Particle physics

text: Quarks cannot exist on their own but form hadrons. Hadrons that contain an odd number of quarks are called baryons and those that contain an even number are called mesons. Two baryons, the proton and the neutron, make up most of the mass of ordinary matter. Mesons are unstable and the longest-lived last for only a few hundredths of a microsecond. They occur after collisions between particles made of quarks, such as fast-moving protons and neutrons in cosmic rays. Mesons are also produced in cyclotrons or other particle accelerators.


title: Particle physics

text: Particles have corresponding antiparticles with the same mass but with opposite electric charges. For example, the antiparticle of the electron is the positron (also known as an antielectron). The electron has a negative electric charge, the positron has a positive charge. These antiparticles can theoretically form a corresponding form of matter called antimatter. Some particles, such as the photon, are their own antiparticle.


title: Particle physics

text: These elementary particles are excitations of the quantum fields that also govern their interactions. The dominant theory explaining these fundamental particles and fields, along with their dynamics, is called the Standard Model. The reconciliation of gravity to the current particle physics theory is not solved; many theories have addressed this problem, such as loop quantum gravity, string theory and supersymmetry theory.


title: Particle physics

text: Practical particle physics is the study of these particles in radioactive processes and in particle accelerators such as the Large Hadron Collider. Theoretical particle physics is the study of these particles in the context of cosmology and quantum theory. The two are closely interrelated: the Higgs boson was postulated by theoretical particle physicists and its presence confirmed by practical experiments.


title: Particle physics

text: The idea that all matter is fundamentally composed of elementary particles dates from at least the 6th century BC. In the 19th century, John Dalton, through his work on stoichiometry, concluded that each element of nature was composed of a single, unique type of particle. The word "atom", after the Greek word "atomos" meaning "indivisible", has since then denoted the smallest particle of a chemical element, but physicists soon discovered that atoms are not, in fact, the fundamental particles of nature, but are conglomerates of even smaller particles, such as the electron. The early 20th century explorations of nuclear physics and quantum physics led to proofs of nuclear fission in 1939 by Lise Meitner (based on experiments by Otto Hahn), and nuclear fusion by Hans Bethe in that same year; both discoveries also led to the development of nuclear weapons.


title: Particle physics

text: Throughout the 1950s and 1960s, a bewildering variety of particles were found in collisions of particles from beams of increasingly high energy. It was referred to informally as the "particle zoo". Important discoveries such as the CP violation by James Cronin and Val Fitch brought new questions to matter-antimatter imbalance. After the formulation of the Standard Model during the 1970s, physicists clarified the origin of the particle zoo. The large number of particles was explained as combinations of a (relatively) small number of more fundamental particles and framed in the context of quantum field theories. This reclassification marked the beginning of modern particle physics.


title: Particle physics

text: The current state of the classification of all elementary particles is explained by the Standard Model, which gained widespread acceptance in the mid-1970s after experimental confirmation of the existence of quarks. It describes the strong, weak, and electromagnetic fundamental interactions, using mediating gauge bosons. The species of gauge bosons are eight gluons, , and bosons, and the photon. The Standard Model also contains 24 fundamental fermions (12 particles and their associated anti-particles), which are the constituents of all matter. Finally, the Standard Model also predicted the existence of a type of boson known as the Higgs boson. On 4 July 2012, physicists with the Large Hadron Collider at CERN announced they had found a new particle that behaves similarly to what is expected from the Higgs boson.


title: Particle physics

text: The Standard Model, as currently formulated, has 61 elementary particles. Those elementary particles can combine to form composite particles, accounting for the hundreds of other species of particles that have been discovered since the 1960s. The Standard Model has been found to agree with almost all the experimental tests conducted to date. However, most particle physicists believe that it is an incomplete description of nature and that a more fundamental theory awaits discovery (See Theory of Everything). In recent years, measurements of neutrino mass have provided the first experimental deviations from the Standard Model, since neutrinos do not have mass in the Standard Model.


title: Particle physics

text: Modern particle physics research is focused on subatomic particles, including atomic constituents, such as electrons, protons, and neutrons (protons and neutrons are composite particles called baryons, made of quarks), that are produced by radioactive and scattering processes; such particles are photons, neutrinos, and muons, as well as a wide range of exotic particles. All particles and their interactions observed to date can be described almost entirely by the Standard Model.


title: Particle physics

text: Dynamics of particles are also governed by quantum mechanics; they exhibit wave–particle duality, displaying particle-like behaviour under certain experimental conditions and wave-like behaviour in others. In more technical terms, they are described by quantum state vectors in a Hilbert space, which is also treated in quantum field theory. Following the convention of particle physicists, the term "elementary particles" is applied to those particles that are, according to current understanding, presumed to be indivisible and not composed of other particles.


title: Particle physics

text: Ordinary matter is made from first-generation quarks (up, down) and leptons (electron, electron neutrino). Collectively, quarks and leptons are called fermions, because they have a quantum spin of half-integers (-1/2, 1/2, 3/2, etc.). This cause the fermions to obey the Pauli exclusion principle, where no two particles may occupy the same quantum state. Quarks have fractional elementary electric charge (-1/3 or 2/3) and leptons have whole-numbered electric charge (0 or 1). Quarks also have color charge, which is labeled arbitrarily with no correlation to actual light color as red, green and blue. Because the interactions between the quarks stores energy which can convert to other particles when the quarks are far apart enough, quarks cannot be observed independently. This is called color confinement.


title: Particle physics

text: There are three known generations of quarks (up and down, strange and charm, top and bottom) and leptons (electron and its neutrino, muon and its neutrino, tau and its neutrino), with strong indirect evidence that the fourth generation of fermions doesn't exist.


title: Particle physics

text: Bosons are the mediators or carriers of fundamental interactions, such as electromagnetism, the weak interaction, and the strong interaction. Electromagnetism is mediated by the photon, the quanta of light. The weak interaction is mediated by the W and Z bosons. The strong interaction is mediated by the gluon, which can link quarks together to form composite particles. Due to the aforementioned color confinement, gluons are never observed independently. The Higgs boson gives mass to the W and Z bosons via the Higgs mechanism – the gluon and photon are expected to be massless. All bosons have an integer quantum spin (0 and 1) and can have the same quantum state.


title: Particle physics

text: Most aforementioned particles have corresponding antiparticles, which compose antimatter. Normal particles have positive lepton or baryon number, and antiparticles have these numbers negative. Most properties of corresponding antiparticles and particles are the same, with a few gets reversed; the electron's antiparticle, positron, has an opposite charge. To differentiate between antiparticles and particles, a plus or negative sign is added in superscript. For example, the electron and the positron are denoted and . When a particle and an antiparticle interacts with each other, they are annihilated and convert to other particles. Some particles have no antiparticles, such as the photon or gluon.


title: Particle physics

text: Quarks and gluons additionally have color charges, which influences the strong interaction. Quark's color charges are called red, green and blue (though the particle itself have no physical color), and in antiquarks are called antired, antigreen and antiblue. The gluon can have eight color charges, which are the result of quarks' interactions to form composite particles (gauge symmetry SU(3)).


title: Particle physics

text: The neutrons and protons in the atomic nuclei are baryons – the neutron is composed of two down quarks and one up quark, and the proton is composed of two up quarks and one down quark. A baryon is composed of three quarks, and a meson is composed of two quarks (one normal, one anti). Baryons and mesons are collectively called hadrons. Quarks inside hadrons are governed by the strong interaction, thus are subjected to quantum chromodynamics (color charges). The bounded quarks must have their color charge to be neutral, or "white" for analogy with mixing the primary colors. More exotic hadrons can have other types, arrangement or number of quarks (tetraquark, pentaquark).


title: Particle physics

text: A normal atom is made from protons, neutrons and electrons. By modifying the particles inside a normal atom, exotic atoms can be formed. A simple example would be the hydrogen-4.1, which has one of its electrons replaced with a muon.


title: Particle physics

text: Graviton is a hypothetical particle that can mediate the gravitational interaction, but it has not been detected nor completely reconciled with current theories.


title: Particle physics

text: Theoretical particle physics attempts to develop the models, theoretical framework, and mathematical tools to understand current experiments and make predictions for future experiments (see also theoretical physics). There are several major interrelated efforts being made in theoretical particle physics today.


title: Particle physics

text: One important branch attempts to better understand the Standard Model and its tests. Theorists make quantitative predictions of observables at collider and astronomical experiments, which along with experimental measurements is used to extract the parameters of the Standard Model with less uncertainty. This work probes the limits of the Standard Model and therefore expands scientific understanding of nature's building blocks. Those efforts are made challenging by the difficulty of calculating high precision quantities in quantum chromodynamics. Some theorists working in this area use the tools of perturbative quantum field theory and effective field theory, referring to themselves as phenomenologists. Others make use of lattice field theory and call themselves "lattice theorists".


title: Particle physics

text: Another major effort is in model building where model builders develop ideas for what physics may lie beyond the Standard Model (at higher energies or smaller distances). This work is often motivated by the hierarchy problem and is constrained by existing experimental data. It may involve work on supersymmetry, alternatives to the Higgs mechanism, extra spatial dimensions (such as the Randall–Sundrum models), Preon theory, combinations of these, or other ideas.


title: Particle physics

text: A third major effort in theoretical particle physics is string theory. "String theorists" attempt to construct a unified description of quantum mechanics and general relativity by building a theory based on small strings, and branes rather than particles. If the theory is successful, it may be considered a "Theory of Everything", or "TOE".


title: Particle physics

text: There are also other areas of work in theoretical particle physics ranging from particle cosmology to loop quantum gravity.


title: Particle physics

text: In principle, all physics (and practical applications developed therefrom) can be derived from the study of fundamental particles. In practice, even if "particle physics" is taken to mean only "high-energy atom smashers", many technologies have been developed during these pioneering investigations that later find wide uses in society. Particle accelerators are used to produce medical isotopes for research and treatment (for example, isotopes used in PET imaging), or used directly in external beam radiotherapy. The development of superconductors has been pushed forward by their use in particle physics. The World Wide Web and touchscreen technology were initially developed at CERN. Additional applications are found in medicine, national security, industry, computing, science, and workforce development, illustrating a long and growing list of beneficial practical applications with contributions from particle physics.


title: Particle physics

text: The primary goal, which is pursued in several distinct ways, is to find and understand what physics may lie beyond the standard model. There are several powerful experimental reasons to expect new physics, including dark matter and neutrino mass. There are also theoretical hints that this new physics should be found at accessible energy scales.


title: Particle physics

text: Much of the effort to find this new physics are focused on new collider experiments. The Large Hadron Collider (LHC) was completed in 2008 to help continue the search for the Higgs boson, supersymmetric particles, and other new physics. An intermediate goal is the construction of the International Linear Collider (ILC), which will complement the LHC by allowing more precise measurements of the properties of newly found particles. In August 2004, a decision for the technology of the ILC was taken but the site has still to be agreed upon.


title: Particle physics

text: There are important non-collider experiments that attempt to find and understand physics beyond the Standard Model. One is the determination of the neutrino masses, since these masses may arise from neutrinos mixing with very heavy particles. Another is cosmological observations that provide constraints on the dark matter, although it may be impossible to determine the exact nature of the dark matter without the colliders. Finally, lower bounds on the very long lifetime of the proton put constraints on Grand Unified Theories at energy scales much higher than collider experiments will be able to probe any time soon.


title: Particle physics

text: In May 2014, the Particle Physics Project Prioritization Panel released its report on particle physics funding priorities for the United States over the next decade. This report emphasized continued U.S. participation in the LHC and ILC, and expansion of the Deep Underground Neutrino Experiment, among other recommendations.


title: The Great British Bake Off (series 12)

text: The twelfth series of "The Great British Bake Off" began airing on 21 September 2021. It is presented by Noel Fielding and Matt Lucas, and judged by returning judges Paul Hollywood and Prue Leith. The bakers were announced on 14 September 2021.


title: The Great British Bake Off (series 12)

text: The series was won by Giuseppe Dell'Anno, with Chigs Parmar and Crystelle Pereira finishing as the runners-up. Dell'Anno is the first Italian winner of the programme. Baker Freya Cox, who was the series' first vegan contestant, published the cookbook "Simply Vegan Baking" in 2022.


title: The Great British Bake Off (series 12)

text: For the signature challenge, the bakers were tasked with making 12 decorative mini rolls, in two hours. The technical challenge, set by Prue, required the bakers to make a malt loaf served with homemade butter, in two hours. In the showstopper challenge, the bakers were given four hours to create an anti-gravity illusion cake, representing a precious memory.


title: The Great British Bake Off (series 12)

text: For the signature challenge, the bakers were tasked with making 24 identical Brandy snaps, in two hours. The technical challenge, set by Paul, required the bakers to make 12 sandwiched jammy biscuits, consisting of two baked biscuits, jam, and buttercream, in one hour and 45 minutes. For the showstopper challenge, the bakers needed to create a 3D biscuit replica of a favorite childhood toy. The replica needed to have an interactive element.


title: The Great British Bake Off (series 12)

text: The signature challenge tasked the bakers with making a focaccia in 2 hours 45 minutes. The technical challenge, set by Paul, tasked the bakers with making 15 olive and cheese ciabatta breadsticks, served with a tzatziki dip, in two hours. For the showstopper challenge, the bakers were asked to create a 3D themed display using milk bread, in four hours and 30 minutes.


title: The Great British Bake Off (series 12)

text: The signature challenge tasked the bakers with making a beautifully decorated Pavlova, in two hours 45 minutes. For the technical challenge, set by Prue, asked the bakers to make 4 individual sticky toffee puddings, served with sticky toffee sauce, two Tuile triangles, and a creme anglaise. The bakers had 90 minutes. For the showstopper challenge, the bakers were given the enormous task of making a celebratory joconde imprime dessert, composed of a highly decorated joconde sponge wrapped around at least two elements, in four hours and 30 minutes.


title: The Great British Bake Off (series 12)

text: The signature challenge tasked the bakers with making two types of 12 German biscuits, which needed to be dipped, coated, or decorated, in two hours 15 minutes. For the technical challenge, Prue asked the bakers to make a Prinzregententorte, consisting of 8 thin layers of genoises sponge sandwiched with chocolate cream, coated with a shiny chocolate ganache, decorated with rosettes and tempered chocolate crowns, in two hours 45 minutes. The showstopper gave the bakers four and a half hours to produce a yeast-leavened cake. The cakes must be at least two-tiered and inspired by the yeasted cakes popular in Germany.


title: The Great British Bake Off (series 12)

text: For the signature, the bakers were tasked with making two batches of glazed or iced chouxnuts: 6 filled, 6 not filled. For the technical challenge, Paul required the bakers to make a large baklava. They were asked to layer Filo pastry with a pistachio and walnut filling, cut into a star design, in two hours and 45 minutes. For the showstopper, the bakers were given the intricate task of making a Terrine pie, in four and a half hours. The pies needed to have an ornated pastry decoration on the outside and a neat pattern or design when cut open.


title: The Great British Bake Off (series 12)

text: For the first signature challenge, the bakers were required to produce a sharing-sized decorative caramel tart in 2 hours and 30 minutes. The technical challenge was set by Paul where the bakers were tasked to make 10 caramel biscuit bars in 1 hour and 30 minutes. For the showstopper challenge, the bakers were required to make a caramel-flavored dessert with a sugar-work dome or sphere in 4 hours and 30 minutes.


title: The Great British Bake Off (series 12)

text: For the signature bake, the bakers were given the challenge of baking 8 dairy-free ice cream sandwiches. They were given 3 hours for the bake. For the technical challenge was to make eight identical vegan sausage rolls accompanied by a sticky red onion chutney, in two hours. In the showstopper, the bakers needed to make a Gluten-free Celebration Cake with at least two tiers. They were given four and a half hours for the bake.


title: The Great British Bake Off (series 12)

text: In the semifinal signature challenge, the bakers were tasked to make 8 pâtisserie-style layered slices in 3 hours. For the technical bake, set by Prue, the bakers are tasked in making a Sablé Breton Tart, consisting of a sablé breton pastry base, topped with raspberry confiture, piped with pistachio crème mousseline, filled with fresh berries and topped with glided meringue kisses and chocolate curls, all in 2 hours and 45 minutes. A themed banquet display consisting of a crafted edible centrepiece surrounded by least 12 individual entremets desserts was set as the showstopper, the bakers are given 5 hours.


title: The Great British Bake Off (series 12)

text: Jurgen's elimination received public backlash following the episode's airing with OFCOM receiving 115 complaints.


title: The Great British Bake Off (series 12)

text: The finalists were set the task of making a carrot cake in 2 hours and 15 minutes for the signature challenge. For the final technical challenge, set by Paul, the bakers were given 2 hours and 30 minutes to create 12 Belgian buns filled with sultanas and lemon curd, with only 2 instructions given. For the ultimate showstopper challenge, the bakers were tasked to make a Mad Hatter tea party display with sweet and savory afternoon tea treats, showcasing at least 4 different baking disciplines in 4 1/2 hours. The judges expect to see the madness feel of Alice in Wonderland in the bakes.


title: The Great British Bake Off (series 12)

text: The Great Christmas Bake Off featured It's a Sin's Olly Alexander, Nathaniel Curtis, Lydia West and Shaun Dooley.


title: The Great British Bake Off (series 12)

text: The signature challenge required the bakers to make a Christmas Dinner's leftovers pie, in 2 hours, it can be made with any type of pastry, but the fillings must be made with leftovers from the baker's favorite Christmas Dinner. Prue's technical challenge tasked the bakers with making a chocolate Yule Log, in 1 hours and 15 minutes. The bakers were given 3 hours to make a Christmas Tree out of biscuit or meringue for the showstopper challenge.


title: The Great British Bake Off (series 12)

text: The Great New Year Bake Off features Jon Jenkins and Kim-Joy Hewlett from Series 9, along with Rowan Williams and Hermine from Series 11.


title: The Great British Bake Off (series 12)

text: For the signature challenge, the bakers were asked to create 12 buns, suitable for a New Year's day Breakfast, the buns can be any flavor or shape, but must be yeasted and feature a topping of the baker's choice, 3 hours are given. Paul's technical challenge required the bakers to make a New Years Eve cake inspired by the traditional Greek Vasilopita, consisting of a perfectly baked lemon mahleb and mastika sponge and decorated with water icing, lemon curd and crystallized citrus peel in 1 hour and 30 minutes. A shadow box winter scene with a frame, to all be created with at least 3 different biscuits in 4 hours is the showstopper.


title: The Great British Bake Off (series 12)

text: "Bake Off" launched with 5.7 million viewers and a 30.8% share – its lowest overnight rating since its move to Channel 4 in 2017 – down 1.3 million on 2020. However, it was the show's biggest ever launch episode on Channel 4 in terms of younger viewers, securing 61.9% of all young viewers watching TV at the time of broadcast.


title: The Great British Bake Off (series 12)

text: At 9.73 million, the Series 12 final was the show's least watched since the Series 4 final which drew 9.45 million. Despite this, the series averaged 9.56 million viewers per episode - down 1.5 million on Series 11 - but on par with every other series since the show's move to Channel 4.


title: Tax haven

text: A tax haven is a jurisdiction with very low "effective" rates of taxation for foreign investors ("headline" rates may be higher). In some traditional definitions, a tax haven also offers financial secrecy. However, while countries with high levels of secrecy but also high rates of taxation, most notably the United States and Germany in the Financial Secrecy Index ("FSI") rankings, can be featured in some tax haven lists, they are not universally considered as tax havens. In contrast, countries with lower levels of secrecy but also low "effective" rates of taxation, most notably Ireland in the FSI rankings, appear in most . The consensus on "effective tax rates" has led academics to note that the term "tax haven" and "offshore financial centre" are almost synonymous.


title: Tax haven

text: Traditional tax havens, like Jersey, are open about zero rates of taxation, but as a consequence have limited bilateral tax treaties. Modern corporate tax havens have non-zero "headline" rates of taxation and high levels of OECD compliance, and thus have large networks of bilateral tax treaties. However, their base erosion and profit shifting ("BEPS") tools enable corporates to achieve "effective" tax rates closer to zero, not just in the haven but in all countries with which the haven has tax treaties; putting them on tax haven lists. According to modern studies, the include corporate-focused havens like the Netherlands, Singapore, Ireland, and the U.K., while Luxembourg, Hong Kong, the Cayman Islands, Bermuda, the British Virgin Islands, and Switzerland feature as both major traditional tax havens and major corporate tax havens. Corporate tax havens often serve as "conduits" to traditional tax havens.


title: Tax haven

text: Use of tax havens results in a loss of tax revenues to countries which are not tax havens. Estimates of the of taxes avoided vary, but the most credible have a range of US$100–250 billion per annum. In addition, capital held in tax havens can permanently leave the tax base (base erosion). Estimates of capital held in tax havens also vary: the most credible estimates are between US$7–10 trillion (up to 10% of global assets). The harm of traditional and corporate tax havens has been particularly noted in developing nations, where the tax revenues are needed to build infrastructure.


title: Tax haven

text: Over 15% of countries are sometimes labelled tax havens. Tax havens are mostly successful and well-governed economies, and being a haven has brought prosperity. The top 10–15 GDP-per-capita countries, excluding oil and gas exporters, are tax havens. Because of (due to accounting BEPS flows), havens are prone to over-leverage (international capital misprice the artificial debt-to-GDP). This can lead to severe credit cycles and/or property/banking crises when international capital flows are repriced. Ireland's Celtic Tiger, and the subsequent financial crisis in 2009–13, is an example. Jersey is another. Research shows , and use of tax havens by U.S corporates maximised U.S. exchequer receipts.


title: Tax haven

text: Historical focus on combating tax havens (e.g. OECD–IMF projects) had been on common standards, transparency and data sharing. The rise of OECD-compliant corporate tax havens, whose BEPS tools were responsible for most of the lost taxes, led to criticism of this approach, versus actual taxes paid. Higher-tax jurisdictions, such as the United States and many member states of the European Union, departed from the OECD BEPS Project in 2017–18 to introduce anti-BEPS tax regimes, targeted raising net taxes paid by corporations in corporate tax havens (e.g. the U.S. Tax Cuts and Jobs Act of 2017 ("TCJA") GILTI–BEAT–FDII tax regimes and move to a hybrid "territorial" tax system, and proposed EU Digital Services Tax regime, and EU Common Consolidated Corporate Tax Base).


title: Tax haven

text: There is no established consensus regarding a specific definition for what constitutes a tax haven. This is the conclusion from non-governmental organisations, such as the Tax Justice Network in 2018, from the 2008 investigation by the U.S. Government Accountability Office, from the 2015 investigation by the U.S. Congressional Research Service, from the 2017 investigation by the European Parliament, and from leading academic researchers of tax havens.


title: Tax haven

text: The issue, however, is material, as being labelled a "tax haven" has consequences for a country seeking to develop and trade under bilateral tax treaties. When Ireland was "blacklisted" by G20 member Brazil in 2016, bilateral trade declined.


title: Tax haven

text: One of the first , was the 1994 Hines–Rice paper by James R. Hines Jr. It is the most cited paper on tax haven research, even in late 2017, and Hines is the most cited author on tax haven research. As well as offering insights into tax havens, it took the view that the diversity of countries that become tax havens was so great that detailed definitions were inappropriate. Hines merely noted that tax havens were: "a group of countries with unusually low tax rates". Hines reaffirmed this approach in a 2009 paper with Dhammika Dharmapala.


title: Tax haven

text: In December 2008, Dharmapala wrote that the OECD process had removed much of the need to include "bank secrecy" in any definition of a tax haven and that it was now "first and foremost, low or zero corporate tax rates", and this has become the general "financial dictionary" definition of a tax haven.


title: Tax haven

text: Hines refined his definition in 2016 to incorporate research on on governance, which is broadly accepted in the academic lexicon.


title: Tax haven

text: In April 1998, the OECD produced a definition of a tax haven, as meeting "three of four" criteria. It was produced as part of their "Harmful Tax Competition: An Emerging Global Issue" initiative. By 2000, when the OECD published their first list of tax havens, it included no OECD member countries as they were now all considered to have engaged in the OECD's new Global Forum on Transparency and Exchange of Information for Tax Purposes, and therefore would not meet "Criteria ii" and "Criteria iii". As the OECD has never listed any of its 35 members as tax havens, Ireland, Luxembourg, the Netherlands, and Switzerland are sometimes defined as the "OECD tax havens".


title: Tax haven

text: In 2017, only Trinidad & Tobago met the 1998 OECD definition; that definition thus fell into disrepute.


title: Tax haven

text: (†) The 4th criterion was withdrawn after objections from the new U.S. Bush Administration in 2001, and in the OECD's 2002 report the definition became "two of three criteria".


title: Tax haven

text: The 1998 OECD definition is most frequently invoked by the "OECD tax havens". However, that definition (as noted above) lost credibility when, in 2017, under its parameters, only Trinidad & Tobago qualified as a tax haven and has since been largely discounted by tax haven academics, including the 2015 U.S. Congressional Research Service investigation into tax havens, as being restrictive, and enabling Hines' low-tax havens (e.g. to which the first criterion applies), to avoid the OECD definition by improving OECD corporation (so the second and third criteria do not apply).


title: Tax haven

text: In April 2000, the Financial Stability Forum (or FSF) defined the related concept of an offshore financial centre (or OFC), which the IMF adopted in June 2000, producing a list of 46 OFCs. The FSF–IMF definition focused on the BEPS tools havens offer, and on Hines' observation that the accounting flows from BEPS tools are "out-of-proportion" and thus distort the economic statistics of the haven. The FSF–IMF list captured new corporate tax havens, such as the Netherlands, which Hines considered too small in 1994. In April 2007, the IMF used a more quantitative approach to generate a list of 22 major OFCs, and in 2018 listed the 8 major OFCs who handle 85% of all flows. From about 2010, tax academics considered OFCs and tax havens to be synonymous terms.


title: Tax haven

text: In October 2010, Hines published a list of 52 tax havens, which he had scaled quantitatively by analysing corporate investment flows. Hines' largest havens were dominated by corporate tax havens, who Dharmapala noted in 2014 accounted for the bulk of global tax haven activity from BEPS tools. The Hines 2010 list was the first to estimate the ten largest global tax havens, only two of which, Jersey and the British Virgin Isles, were on the OECD's 2000 list.


title: Tax haven

text: In July 2017, the University of Amsterdam's CORPNET group ignored any definition of a tax haven and focused on a purely quantitive approach, analysing 98 million global corporate connections on the Orbis database. CORPNET's lists of top five Conduit OFCs, and top five Sink OFCs, matched 9 of the top 10 havens in Hines' 2010 list, only differing in the United Kingdom, which only transformed their tax code in 2009–12. CORPNET's Conduit and Sink OFCs study split the understanding of a tax haven into two classifications:


title: Tax haven

text: In June 2018, tax academic Gabriel Zucman ("et alia") published research that also ignored any definition of a tax haven, but estimated the corporate "profit shifting" (i.e. BEPS), and "enhanced corporate profitability" that Hines and Dharmapala had noted. Zucman pointed out that the CORPNET research under-represented havens associated with US technology firms, like Ireland and the Cayman Islands, as Google, Facebook and Apple do not appear on Orbis. Even so, Zucman's 2018 list of top 10 havens also matched 9 of the top 10 havens in Hines' 2010 list, but with Ireland as the largest global haven. These lists (Hines 2010, CORPNET 2017 and Zucman 2018), and others, which followed a purely quantitive approach, showed a firm consensus around the largest corporate tax havens.


title: Tax haven

text: In October 2009, the Tax Justice Network introduced the Financial Secrecy Index ("FSI") and the term "secrecy jurisdiction", to highlight issues in regard to OECD-compliant countries who have high tax rates and do not appear on academic lists of tax havens, but have transparency issues. The FSI does not assess tax rates or BEPS flows in its calculation; but it is often misinterpreted as a tax haven definition in the financial media, particularly when it lists the US and Germany as major "secrecy jurisdictions". However, many types of tax havens also rank as secrecy jurisdictions.


title: Tax haven

text: While tax havens are diverse and varied, tax academics sometimes recognise three major "groupings" of tax havens when discussing the history of their development:


title: Tax haven

text: As discussed in , the first recognized tax haven hub was the Zurich-Zug-Liechtenstein triangle created in the mid-1920s, later joined by Luxembourg in 1929. Privacy and secrecy were established as an important aspect of European tax havens. However, modern European tax havens also include corporate-focussed tax havens, which maintain higher levels of OECD transparency, such as the Netherlands and Ireland. European tax havens act as an important part of the global flows to tax havens, with three of the five major global Conduit OFCs being European (e.g. the Netherlands, Switzerland, and Ireland). Four European-related tax havens appear in the various notable lists, namely: the Netherlands, Ireland, Switzerland, and Luxembourg.


title: Tax haven

text: Many tax havens are former or current dependencies of the United Kingdom and still use the same core legal structures. Six British Empire-related tax havens appear in the lists, namely: Caribbean tax havens (e.g., Bermuda, the British Virgin Islands, and the Cayman Islands), Channel Islands tax havens (e.g. Jersey) and Asian tax havens (e.g., Singapore and Hong Kong). As discussed in , the United Kingdom created its first "non-resident company" in 1929, and led the Eurodollar offshore financial centre market post World War II. Since the reform of its corporate tax code in 2009–2012, the UK has re-emerged as a major corporate-focused tax haven. Two of the five major global Conduit OFCs are from this grouping (e.g. the U.K. and Singapore).


title: Tax haven

text: In November 2009, Michael Foot, a former Bank of England official and Bahamas bank inspector, delivered an integrated report on the three British Crown Dependencies (Guernsey, Isle of Man and Jersey), and the six Overseas Territories (Anguilla, Bermuda, British Virgin Islands, Cayman Islands, Gibraltar, Turks and Caicos Islands), "to identify the opportunities and challenges as offshore financial centres", for the HM Treasury.


title: Tax haven

text: As discussed in , most of these tax havens date from the late 1960s and effectively copied the structures and services of the above groups. Most of these tax havens are not OECD members, or in the case of British Empire-related tax havens, do not have a senior OECD member at their core. Some have suffered setbacks during various OECD initiatives to curb tax havens (e.g. Vanuatu and Samoa). However, others such as Taiwan (for AsiaPAC), and Mauritius (for Africa), have grown materially in the past decades. Taiwan has been described as "Switzerland of Asia", with a focus on secrecy. Although no Emerging market-related tax haven ranks in the five major global Conduit OFCs or any lists, both Taiwan and Mauritius rank in the top ten global Sink OFCs.


title: Tax haven

text: The post–2010 rise in quantitative techniques of identifying tax havens has resulted in a more stable list of the largest tax havens. Dharmapala notes that as corporate BEPS flows dominate tax haven activity, these are mostly corporate tax havens. Nine of the top ten tax havens in Gabriel Zucman's June 2018 study also appear in the top ten lists of the two other quantitative studies since 2010. Four of the top five Conduit OFCs are represented; however, the UK only transformed its tax code in 2009–2012. All five of the top 5 Sink OFCs are represented, although Jersey only appears in the Hines 2010 list.


title: Tax haven

text: The studies capture the rise of Ireland and Singapore, both major regional headquarters for some of the largest BEPS tool users, Apple, Google and Facebook. In Q1 2015, Apple completed the largest BEPS action in history, when it shifted US$300 billion of IP to Ireland, which Nobel-prize economist Paul Krugman called "leprechaun economics". In September 2018, using TCJA repatriation tax data, the NBER listed the "key tax havens" as: "Ireland, Luxembourg, Netherlands, Switzerland, Singapore, Bermuda and [the] Caribbean havens".


title: Tax haven

text: (*) Appears as a top ten tax haven in all three lists; 9 major tax havens meet this criterion, "Ireland, Singapore, Switzerland and the Netherlands (the Conduit OFCs), and the Cayman Islands, British Virgin Islands, Luxembourg, Hong Kong and Bermuda (the Sink OFCs)".


title: Tax haven

text: (†) Also appears as one of 5 Conduit OFC (Ireland, Singapore, Switzerland, the Netherlands, and the United Kingdom), in CORPNET's 2017 research; or


title: Tax haven

text: (‡) Also appears as a Top 5 Sink OFC (British Virgin Islands, Luxembourg, Hong Kong, Jersey, Bermuda), in CORPNET's 2017 research.


title: Tax haven

text: (Δ) Identified on the first, and largest, OECD 2000 list of 35 tax havens (the OECD list only contained Trinidad & Tobago by 2017).


title: Tax haven

text: The strongest consensus amongst academics regarding the world's largest tax havens is therefore: Ireland, Singapore, Switzerland and the Netherlands (the major Conduit OFCs), and the Cayman Islands, British Virgin Islands, Luxembourg, Hong Kong and Bermuda (the major Sink OFCs), with the United Kingdom (a major Conduit OFC) still in transformation.


title: Tax haven

text: Of these ten major havens, all except the United Kingdom and the Netherlands featured on the original Hines–Rice 1994 list. The United Kingdom was not a tax haven in 1994, and Hines estimated the Netherlands's effective tax rate in 1994 at over 20%. (Hines identified Ireland as having the lowest effective tax rate at 4%.) Four of these: Ireland, Singapore, Switzerland (3 of the 5 top Conduit OFCs), and Hong Kong (a top 5 Sink OFC), featured in the Hines–Rice 1994 list's "7 major tax havens" subcategory; highlighting a lack of progress in curtailing tax havens.


title: Tax haven

text: In terms of proxy indicators, this list, excluding Canada, contains all seven of the countries that received more than one US tax inversion since 1982 (see here). In addition, six of these major tax havens are in the top 15 GDP-per-capita, and of the four others, three of them, the Caribbean locations, are not included in IMF-World Bank GDP-per-capita tables.


title: Tax haven

text: In a June 2018 joint IMF report into the effect of BEPS flows on global economic data, eight of the above (excluding Switzerland and the United Kingdom) were cited as the world's leading tax havens.


title: Tax haven

text: The longest list from "Non–governmental, Quantitative" research on tax havens is the University of Amsterdam CORPNET July 2017 Conduit and Sink OFCs study, at 29 (5 Conduit OFCs and 25 Sink OFCs). The following are the 20 largest (5 Conduit OFCs and 15 Sink OFCs), which reconcile with other main lists as follows:


title: Tax haven

text: (*) Appears in as a in all three quantitative lists, Hines 2010, ITEP 2017 and Zucman 2018 (above); all nine such s are listed below.


title: Tax haven

text: (♣) Appears on the James Hines 2010 list of 52 tax havens; 17 of the 20 locations below, are on the James Hines 2010 list.


title: Tax haven

text: (Δ) Identified on the largest OECD 2000 list of 35 tax havens (the OECD list only contained Trinidad & Tobago by 2017); only four locations below were ever on an OECD list.


title: Tax haven

text: (↕) Identified on the European Union's first 2017 list of 17 tax havens; only one location below is on the EU 2017 list.


title: Tax haven

text: Sovereign states or autonomous regions that feature as both major corporate tax havens and major traditional tax havens:


title: Tax haven

text: Sovereign (including de facto) states that feature mainly as traditional tax havens (but have non-zero tax rates):


title: Tax haven

text: Sovereign or sub-national states that are very traditional tax havens (i.e. explicit 0% rate of tax) include (fuller list in table opposite):


title: Tax haven

text: Post–2010 research on tax havens is focused on quantitative analysis (which can be ranked), and tends to ignore very small tax havens where data is limited as the haven is used for individual tax avoidance rather than corporate tax avoidance. The last credible broad unranked list of global tax havens is the James Hines 2010 list of 52 tax havens. It is shown below but expanded to 55 to include havens identified in the July 2017 Conduit and Sink OFCs study that were not considered havens in 2010, namely the United Kingdom, Taiwan, and Curaçao. The James Hines 2010 list contains 34 of the original 35 OECD tax havens; and compared with the and above, show OECD processes focus on the compliance of tiny havens.


title: Tax haven

text: (‡) Identified as one of the largest 24 Sinks by CORPNET in 2017; the above list has 23 of the 24 (Guyana missing).


title: Tax haven

text: (↕) Identified on the European Union's first 2017 list of 17 tax havens; the above list contains 8 of the 17.


title: Tax haven

text: (Δ) Identified on the first, and the largest, OECD 2000 list of 35 tax havens (the OECD list only contained Trinidad & Tobago by 2017); the above list contains 34 of the 35 (U.S. Virgin Islands missing).


title: Tax haven

text: Major sovereign States which feature on financial secrecy lists (e.g. the Financial Secrecy Index), but not on corporate tax haven or traditional tax haven lists, are:


title: Tax haven

text: Neither the U.S. nor Germany have appeared on any tax haven lists by the main academic leaders in tax haven research, namely James R. Hines Jr., Dhammika Dharmapala, or Gabriel Zucman. There are no known cases of foreign firms executing tax inversions to the U.S. or Germany for tax purposes, a basic characteristic of a corporate tax haven.


title: Tax haven

text: Estimating the financial scale of tax havens is complicated by their inherent lack of transparency. Even jurisdictions that comply with OECD–transparency requirements such as Ireland, Luxembourg, and the Netherlands, provide alternate secrecy tools (e.g. Trusts, QIAIFs and ULLs). For example, when the EU Commission discovered Apple's tax rate in Ireland was 0.005%, they found Apple had used Irish ULLs to avoid filing Irish public accounts since the early 1990s.


title: Tax haven

text: Additionally, there is sometimes confusion between figures that focus on the "amount of annual taxes" lost due to tax havens (estimated to be in the hundreds of billions of USD), and figures that focus on the "amount of capital" residing in tax havens (estimated to be in the trillions of USD).


title: Tax haven

text: There have been many other "guesstimates" produced by NGOs which are either crude derivatives of the first method ("Banking data"), and are often criticised for taking mistaken interpretations and conclusions from aggregate global banking and financial data, to produce unsound estimates.


title: Tax haven

text: A notable study on the financial effect was "Price of Offshore: Revisited" in 2012–2014, by former McKinsey & Company chief economist James S. Henry. Henry did the study for the Tax Justice Network (TJN), and as part of his analysis, chronicled the history of past financial estimates by various organisations.


title: Tax haven

text: Henry's credibility and the depth of this analysis meant that the report attracted international attention. The TJN supplemented his report with another report on the consequences of the analysis in terms of global inequality and lost revenues to developing economies. The report was criticised by a 2013 report funded by "Jersey Finance" (a lobby group for the financial services sector in Jersey), and written by two U.S. academics, Richard Morriss and Andrew Gordon. In 2014, the TJN issued a report responding to these criticisms.


title: Tax haven

text: In 2015, French tax economist Gabriel Zucman published "The Hidden Wealth of Nations" which used global national accounts data to calculate the quantum of net foreign asset positions of rich countries which are unreported because there are located in tax havens. Zucman estimated that circa 8–10% of the global financial wealth of households, or over US$7.6 trillion, was held in tax havens.


title: Tax haven

text: Zucman followed up his 2015 book with several co-authored papers that focused on corporate use of tax havens, titled "The Missing Profits of Nations" (2016–2018), and "The Exorbitant Tax Privilege" (2018), which showed that corporations, shield over US$250 billion per annum from taxes. Zucman showed that almost half of these are U.S. corporations, and that it was the driver of how U.S. corporations built up offshore cash deposits of US$1 to 2 trillion since 2004. Zucman's (et alia) analysis showed that global GDP figures were materially distorted by multinational BEPS flows.


title: Tax haven

text: A 2022 study by Zucman and co-authors estimated that 36% of the profits of multinational firms are shifted to tax havens. If the profits had been reallocated to their domestic source, "domestic profits would increase by about 20% in high-tax European Union countries, 10% in the United States, and 5% in developing countries, while they would fall by 55% in tax havens."


title: Tax haven

text: In 2007, the OECD estimated that capital held offshore amounted to between US$5 to 7 trillion, making up approximately 6–8% of total global investments under management. In 2017, as part of the OECD BEPS Project, it estimated that between US$100 to 240 billion in corporate profits where being shielded from taxation via BEPS activities carried out through tax haven type jurisdictions.


title: Tax haven

text: In 2018, the IMF's quarterly journal "Finance & Development" published joint research between the IMF and tax academics titled, "Piercing the Veil", that estimated circa US$12 trillion in global corporate investment worldwide was "just phantom corporate investment" structured to avoid corporate taxation, and was concentrated in eight major locations. In 2019, the same team published further research titled, "The Rise of Phantom Investments", that estimated that a high percentage of global foreign direct investment (FDI) was "phantom", and that "Empty corporate shells in tax havens undermine tax collection in advanced, emerging market, and developing economies". The research singled out Ireland, and estimated that over two-thirds of Ireland's FDI was "phantom".


title: Tax haven

text: In several research papers, James R. Hines Jr. showed that tax havens were typically small but well-governed nations and that being a tax haven had brought significant prosperity. In 2009, Hines and Dharmapala suggested that roughly 15% of countries are tax havens, but they wondered why more countries had not become tax havens given the observable economic prosperity it could bring.


title: Tax haven

text: Hines and Dharmapala concluded that governance was a major issue for smaller countries in trying to become tax havens. Only countries with strong governance and legislation which was trusted by foreign corporates and investors, would become tax havens. Hines and Dharmapala's positive view on the financial benefits of becoming a tax haven, as well as being two of the major academic leaders into tax haven research, put them in sharp conflict with non-governmental organisations advocating "tax justice", such as the Tax Justice Network, who accused them as promoting tax avoidance.


title: Tax haven

text: Tax havens have high GDP-per-capita rankings, as their "headline" economic statistics are artificially inflated by the BEPS flows that add to the haven's GDP, but are not taxable in the haven. As the largest facilitators of BEPS flows, corporate-focused tax havens, in particular, make up most of the top 10-15 GDP-per-capita tables, excluding oil and gas nations (see table below). Research into tax havens suggest a high GDP-per-capita score, in the absence of material natural resources, as an important proxy indicator of a tax haven. At the core of the FSF-IMF definition of an offshore financial centre is a country where the financial BEPS flows are out of proportion to the size of the indigenous economy. Apple's Q1 2015 "leprechaun economics" BEPS transaction in Ireland was a dramatic example, which caused Ireland to abandon its GDP and GNP metrics in February 2017, in favour of a new metric, modified gross national income, or GNI*.


title: Tax haven

text: The artificial inflation of GDP can attract underpriced foreign capital (who use the "headline" Debt-to-GDP metric of the haven), thus producing phases of stronger economic growth. However, the increased leverage leads to more severe credit cycles, particularly where the artificial nature of the GDP is exposed to foreign investors.


title: Tax haven

text: In 2018, noted tax haven economist, Gabriel Zucman, showed that most corporate tax disputes are between high-tax jurisdictions, and not between high-tax and low-tax jurisdictions. Zucman (et alia) research showed that disputes with major havens such as Ireland, Luxembourg and the Netherlands, are actually quite rare.


title: Tax haven

text: A controversial area of research into tax havens is the suggestion that tax havens actually promote global economic growth by solving perceived issues in the tax regimes of higher-taxed nations (e.g. the above discussion on the U.S. "worldwide" tax system as an example). Important academic leaders in tax haven research, such as Hines, Dharmapala, and others, cite evidence that, in certain cases, tax havens appear to promote economic growth in higher-tax countries, and can support beneficial hybrid tax regimes of higher taxes on domestic activity, but lower taxes on international sourced capital or income:


title: Tax haven

text: The most cited paper on research into offshore financial centres ("OFCs"), a closely related term to tax havens, noted the positive and negative aspects of OFCs on neighbouring high-tax, or source, economies, and marginally came out in favour of OFCs.


title: Tax haven

text: However, other notable tax academics strongly dispute these views, such as work by Slemrod and Wilson, who in their , label tax havens as "parasitic" to jurisdictions with normal tax regimes, that can damage their economies. In addition, "tax justice" campaign groups have been equally critical of Hines, and others, in these views. Research in June 2018 by the IMF showed that much of the foreign direct investment ("FDI") that came from tax havens into higher-tax countries, had really originated from the higher-tax country, and for example, that the largest source of FDI into the United Kingdom, was actually from the United Kingdom, but invested via tax havens.


title: Tax haven

text: The boundaries with wider contested economic theories on the effects of corporate taxation on economic growth, and whether there should be corporate taxes, are easy to blur. Other researchers that have examined tax havens, such as Zucman, highlight the injustice of tax havens and see the effects as lost income for the development of society. It remains a controversial area with advocates on both sides.


title: Tax haven

text: A finding of the 1994 Hines-Rice paper, re-affirmed by others, was that: "low foreign tax rates [from tax havens] ultimately enhance U.S. tax collections". Hines showed that as a result of paying no foreign taxes by using tax havens, U.S. multinationals avoided building up foreign tax credits that would reduce their U.S. tax liability. Hines returned to this finding several times, and in his 2010 , "Treasure Islands", where he showed how U.S. multinationals used tax havens and BEPS tools to avoid Japanese taxes on their Japanese investments, noted that this was being confirmed by other empirical research at a company-level. Hines's observations would influence U.S. policy towards tax havens, including the 1996 "check-the-box" rules, and U.S. hostility to OECD attempts in curbing Ireland's BEPS tools, and why, in spite of public disclosure of tax avoidance by firms such as Google, Facebook, and Apple, with Irish BEPS tools, little has been done by the U.S. to stop them.


title: Tax haven

text: Research in June–September 2018, confirmed U.S. multinationals as the largest global users of tax havens and BEPS tools.


title: Tax haven

text: In 2019, non-academic groups, such as the Council on Foreign Relations, realised the scale of U.S. corporate use of tax havens:


title: Tax haven

text: "Tax justice" groups interpreted Hines' research as the U.S. engaging in tax competition with higher-tax nations (i.e. the U.S. exchequer earning excess taxes at the expense of others). The 2017 TCJA seems to support this view with the U.S. exchequer being able to levy a 15.5% repatriation tax on over $1 trillion of untaxed offshore profits built up by U.S. multinationals with BEPS tools from non-U.S. revenues. Had these U.S. multinationals paid taxes on these non-U.S. profits in the countries in which they were earned, there would have been the little further liability to U.S. taxation. Research by Zucman and Wright (2018) estimated that most of the TCJA repatriation benefit went to the shareholders of U.S. multinationals, and not the U.S. exchequer.


title: Tax haven

text: Academics who study tax havens, attribute Washington's support of U.S. corporate use of tax havens to a political compromise between Washington, and other higher-tax OECD nations, to compensate for shortcomings of the U.S. "worldwide" tax system. Hines had advocated for a switch to a "territorial" tax system, as most other nations use, which would remove U.S. multinational need for tax havens. In 2016, Hines, with German tax academics, showed that German multinationals make little use of tax havens because their tax regime, a "territorial" system, removes any need for it.


title: Tax haven

text: Hines' research was cited by the Council of Economic Advisors ("CEA") in drafting the TCJA legislation in 2017, and advocating for moving to a hybrid "territorial" tax system framework.


title: Tax haven

text: There are a number of notable concepts in relation to how individuals and corporates engage with tax havens:


title: Tax haven

text: Some notable authors on tax havens describe them as "captured states" by their offshore finance industry, where the legal, taxation and other requirements of the professional service firms operating from the tax haven are given higher priority to any conflicting State needs. The term is particularly used for smaller tax havens, with examples being Antigua, the Seychelles, and Jersey. However, the term "captured state" has also been used for larger and more established OECD and EU offshore financial centres or tax havens. Ronen Palan has noted that even where tax havens started out as "trading centres", they can eventually become "captured" by "powerful foreign finance and legal firms who write the laws of these countries which they then exploit". Tangible examples include the public disclosure in 2016 of Amazon Inc's Project Goldcrest tax structure, which showed how closely the State of Luxembourg worked with Amazon for over two years to help it avoid global taxes. Other examples include how the Dutch Government removed provisions to prevent corporate tax avoidance by creating the Dutch Sandwich BEPS tool, which Dutch law firms then marketed to US corporations:


title: Tax haven

text: Preferential tax rulings (PTR) can be used by a jurisdiction for benign reasons, for example, tax incentives to encourage urban renewal. However, PTRs can also be used to provide aspects of tax regimes normally found in traditional tax havens. For example, while British citizens pay full taxes on their assets, foreign citizens legally resident in the UK pay no taxes on their global assets, as long as they are left outside the UK; thus, for a foreign resident, the UK behaves in a similar way to a traditional tax haven. Some tax academics say that PTRs make the distinction with traditional tax havens "matter of degree more than anything else". The OECD has made the investigation of PTRs a key part of its long-term project of combatting "Harmful Tax Practices", started in 1998; by 2019, the OECD had investigated over 255 PTRs. The 2014 "Lux Leaks" disclosure revealed 548 PTRs issued by the Luxembourg authorities to corporate clients of PriceWaterhouseCoopers. When the EU Commission fined Apple USD$13 billion in 2016, the largest tax fine in history, they claimed Apple had received "preferential tax rulings" in 1991 and 2007.


title: Tax haven

text: Corporations can move their legal headquarters from a higher-tax home jurisdiction to a tax haven by executing a tax inversion. A "naked tax inversion" is where the corporate had little prior business activities in the new location. The first tax inversion was the "naked inversion" of McDermott International to Panama in 1983. The US Congress effectively banned "naked inversions" for US corporates by introducing IRS regulation 7874 in the American Jobs Creation Act of 2004. A "merger tax inversion" is where the corporate overcomes IRS 7874 by merging with a corporation that has a "substantive business presence" in the new location. The requirement for a substantive business presence meant that US corporations could only invert to larger tax havens, and particularly OECD tax havens and EU tax havens. Further tightening of regulations by the US Treasury in 2016, as well as the 2017 TCJA US tax reform, reduced the tax benefits of a US corporation inverting to a tax haven.


title: Tax haven

text: Even when a corporation executes a tax inversion to a tax haven, it also needs to "shift" (or earnings strip) its untaxed profits to the new tax haven. These are called base erosion and profit shifting (BEPS) techniques. Notable BEPS tools like the Double Irish with a Dutch Sandwich were used by US corporations to build up untaxed offshore cash reserves of US$1–2 trillion in tax havens like Bermuda (e.g., Apple's Bermuda Black Hole) from 2004 to 2017. As discussed in , in 2017, the OECD estimated that BEPS tools shielded US$100 to US$200 billion in annual corporate profits from tax; while in 2018, Zucman estimated that the figure was closer to US$250 billion per annum. This was despite the 2012–2016 OECD BEPS Project. In 2015, Apple executed the largest recorded BEPS transaction in history when it moved US$300 billion of its IP to Ireland, in what was called a hybrid-tax inversion.


title: Tax haven

text: The largest BEPS tools are the ones that use intellectual property (IP) accounting to "shift" profits between jurisdictions. The concept of a corporation charging its costs from one jurisdiction against its profits in another jurisdiction (i.e. transfer pricing) is well understood and accepted. However, IP enables a corporation to "revalue" its costs dramatically. For example, a major piece of software might have cost US$1 billion to develop in salaries and overheads. IP accounting enables the legal ownership of the software to be relocated to a tax haven where it can be revalued to being worth US$100 billion, which becomes the new price at which it is charged out against global profits. This creates a "shifting" of all global profits back to the tax haven. IP has been described as "the leading corporate tax avoidance vehicle".


title: Tax haven

text: Traditional tax havens, such as the Caribbean or Channel Island havens, are often clear about the tax-free nature of their status to individuals and corporates. However, because of this, they are unable to sign full bilateral tax treaties with other higher-tax jurisdictions. Instead, their tax treaties are restricted and limited so as to avoid the use of the tax haven (e.g. withholding taxes on transfers to the haven). To solve this issue, other tax havens maintain higher non-zero "headline" rates of corporate taxation, but instead provide complex and confidential BEPS tools and PTRs which bring the "effective" corporate tax rate closer to zero; they all feature prominently in the leading jurisdictions for IP law (see graphic). These "corporate tax havens" (or Conduit OFCs), further increase respectability by requiring the corporate using their BEPS tools/PTRs to main a "substantial presence" in the haven; this is called an employment tax, and can cost the corporate circa 2–3% of revenues. However, these initiatives enable the corporate tax haven to maintain large networks of full bilateral tax treaties, that allow corporates based in the haven to "shift" global untaxed profits back to the haven (and on to Sink OFCs, as shown above). These "corporate tax havens" strongly deny any association with being a tax haven and maintain high levels of compliance and transparency, with many being OECD-whitelisted (and are OECD or EU members). Many of the are "corporate tax havens".


title: Tax haven

text: In 2017, the University of Amsterdam's CORPNET research group published the results of their multi-year big data analysis of over 98 million global corporate connections. CORPNET ignored any prior definition of a tax haven or any legal or tax structuring concepts, to instead follow a purely quantitative approach. CORPNET's results split the understanding of tax havens into Sink OFCs, which are traditional tax havens to which corporates route untaxed funds, and Conduit OFCs, which are the jurisdictions that create the OECD-compliant tax structures that enable the untaxed funds to be routed from the higher-tax jurisdictions to the Sink OFCs. Despite following a purely quantitative approach, CORPNET's top 5 Conduit OFCs and top 5 Sink OFCs closely match the other academic . CORPNET's Conduit OFCs contained several major jurisdictions considered OECD and/or EU tax havens, including the Netherlands, the United Kingdom, Switzerland, and Ireland. Conduit OFCs are strongly correlated with modern "corporate tax havens" and Sink OFCs with the "traditional tax havens".