Report to Congressional Requesters

United States Government Accountability Office

GAO 

INTERNATIONAL 

TAXATION 

Large U.S. 

Corporations and 

Federal Contractors 

with Subsidiaries in 

Jurisdictions Listed as 

Tax Havens or 

Financial Privacy 

Jurisdictions 

December 2008 

GAO-09-157 
What GAO Found

United States Government Accountability Office

Why GAO Did This Study

Highlights

Accountability Integrity Reliability

December 2008

INTERNATIONAL TAXATION 

Large U.S. Corporations and Federal Contractors with 

Subsidiaries in Jurisdictions Listed as Tax Havens or 

Highlights of GAO-09-157, a report to Financial Privacy Jurisdictions

congressional requesters 

Many U.S. corporations operate 

globally and have foreign 

subsidiaries. The subsidiaries may 

be created, for example, to take 

advantage of sales opportunities or 

favorable labor conditions. In some

cases they may be used to reduce

taxes. GAO was asked to update its 

2004 report on large federal 

contractors with subsidiaries in 

countries sometimes called tax 

havens because of low taxes and a

general lack of transparency. 

In response, GAO determined how 

many of the 100 largest publicly

traded U.S. corporations and the 

100 largest publicly traded U.S.

federal contractors have

subsidiaries in jurisdictions listed 

as tax havens or financial privacy

jurisdictions. 

GAO (1) combined three lists of

such jurisdictions created by 

governmental, international, and 

academic sources and (2) identified

large publicly traded U.S. 

corporations and federal

contractors and the locations of

their subsidiaries using the Fortune 

500 list, a federal contracting Web

site, and a Securities and Exchange

Commission (SEC) database. 

Eighty-three of the 100 largest publicly traded U.S. corporations in terms of 

2007 revenue reported having subsidiaries in jurisdictions listed as tax havens 

or financial privacy jurisdictions. Sixty-three of the 100 largest publicly traded 

U.S. federal contractors in terms of fiscal year 2007 federal contract 

obligations reported having subsidiaries in such jurisdictions. Since 

subsidiaries may be established in listed jurisdictions for a variety of nontax 

business reasons, the existence of a subsidiary in a jurisdiction listed as a tax 

haven or financial privacy jurisdiction does not signify that a corporation or 

federal contractor established that subsidiary for the purpose of reducing its 

tax burden. GAO did not attempt to determine if corporations or contractors 

with subsidiaries in such jurisdictions engaged in transactions with their 

subsidiaries to reduce their tax burden. In addition, the SEC only requires 

public corporations to report significant subsidiaries, so the number of 

subsidiaries in jurisdictions listed as tax havens or financial privacy 

jurisdictions for each corporation or federal contractor may be understated in

this report. 

There is no agreed-upon definition of a tax haven or agreed-upon list of 

jurisdictions that should be considered tax havens. However, various 

governmental, international, and academic sources used similar 

characteristics to define and identify tax havens. Some of the characteristics 

included no or nominal taxes; a lack of effective exchange of information with 

foreign tax authorities; and a lack of transparency in legislative, legal, or 

administrative provisions. A few sources used terms such as offshore financial 

centers or financial privacy jurisdictions to refer to jurisdictions with similar 

characteristics. Based on a review of a variety of sources, GAO identified 

three lists of tax havens or financial privacy jurisdictions. The three sources 

GAO used are (1) the Organization for Economic Co-operation and 

Development, (2) a National Bureau of Economic Research working paper, 

and (3) a U.S. District Court order granting leave for the Internal Revenue 

Service to serve a “John Doe” summons. GAO combined the three lists into 

one for the purposes of this report. GAO did not develop its own definition of 

tax haven or its own list of jurisdictions. 

In commenting on a draft of this report, the Department of the Treasury 

expressed concerns about GAO using a list of tax havens or financial privacy 

jurisdictions because there is no agreed-upon definition of tax havens or list of

jurisdictions. However, GAO noted that there is no agreed-upon definition or 

list and also noted that the jurisdictions on the three lists used have similar 

characteristics. Further, background for one list said that industry analysts 

recognize them as offshore tax haven or financial privacy jurisdictions and 

that they are promoted as such. 

 

 To view the full product, including the scope 

and methodology, click on GAO-09-157. 

For more information, contact James R. White 

at (202) 512-9110 or whitej@gao.gov. 
Contents 

Letter 1

Results 4

Agency Comments and Our Evaluation 6 

Appendix I Objectives, Scope, and Methodology 9 

Appendix II The 100 Largest Publicly Traded U.S. Corporations 21 

Appendix III The 100 Largest Publicly Traded U.S. Federal 

Contractors 40 

Appendix IV Comments from the Department of the Treasury 55 

Appendix V Comments from the Internal Revenue Service 57 

Appendix VI GAO Contact and Staff Acknowledgments 58 

 

Table 

Table 1: Jurisdictions Listed as Tax Havens or Financial Privacy 

Jurisdictions and the Sources of Those Jurisdictions 12 

Page i GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Abbreviations 

EDGAR Electronic Data Gathering, Analysis, and Retrieval database 

FPDS-NG Federal Procurement Data System-Next Generation 

FSF Financial Stability Forum 

IMF International Monetary Fund 

IRS Internal Revenue Service 

NBER National Bureau of Economic Research 

OECD Organization for Economic Co-operation and Development 

SEC Securities and Exchange Commission 

TIEA Tax Information Exchange Agreement

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page ii GAO-09-157 U.S. Corporations with Foreign Subsidiaries
United States Government Accountability Office

Washington, DC 20548 

 

December 18, 2008 

The Honorable Carl Levin 

Chairman, Permanent Subcommittee on Investigations 

Committee on Homeland Security and Governmental Affairs 

United States Senate 

The Honorable Byron L. Dorgan 

United States Senate 

Today, corporations operate in a global economy and most of the largest 

U.S. corporations have subsidiaries in other countries. Corporations have 

foreign subsidiaries for a variety of business reasons, including reasons 

related to taxes. For example, a corporation may establish a foreign 

subsidiary to take advantage of sales opportunities, natural resources, or 

favorable labor conditions. In some cases, U.S. taxpayers aggressively 

interpret U.S. tax law relating to foreign subsidiaries. For example, the 

Department of the Treasury (Treasury) has found that some U.S. 

corporations have aggressively set transfer prices1

 to move income to 

offshore jurisdictions to avoid U.S. taxes.2

 Some offshore jurisdictions 

have no or nominal taxes and are sometimes referred to as tax havens. In

addition, we previously reported that in 2004, for U.S. multinational 

corporations generally the share of business activities related to income 

that are more likely to be affected by income-shifting practices3

 was 

significantly larger in countries with relatively low effective tax rates than

the share of business activities that were least likely to be affected by

 1

Transfer prices are the prices related companies, such as parents and subsidiaries, charge

on intercompany transactions. These prices affect the distribution of profits between the

two companies. 

2

See Department of the Treasury, Report to the Congress on Earnings Stripping, Transfer

Pricing, and U.S. Income Tax Treaties (November 2007). 

3

Income shifting is transferring gross income from one taxpayer to another taxpayer in a

lower tax bracket or jurisdiction, thereby reducing the overall liability of the original 

taxpayer. 

Page 1 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
 

income-shifting practices (physical assets, compensation, and 

employment).4

Because of your interest in U.S. corporations that have subsidiaries in tax 

havens and possible tax avoidance, you asked us to provide information 

about those corporations as well as update similar information about 

federal contractors that we reported in 2004.5

 In this report, as in our 

previous report, we did not attempt to develop a list of tax havens. Instead,

we reviewed various governmental, international, and academic sources 

addressing offshore business activity. We did not find an agreed-upon 

definition of a tax haven or an agreed-upon list of the jurisdictions that 

should be considered tax havens, but the sources we reviewed used 

similar characteristics to define and identify tax havens.6

 In addition, a few 

sources used similar characteristics to describe offshore financial centers 

or financial privacy jurisdictions.7

 For the purposes of this report, we 

combined lists of jurisdictions from three sources and, for brevity 

purposes, will refer to the jurisdictions as jurisdictions listed as tax havens

or financial privacy jurisdictions. We did not develop our own definition of 

a tax haven or our own list of jurisdictions. Our objectives in this report 

were to 

• determine how many of the 100 largest publicly traded U.S. corporations 

in terms of revenue have subsidiaries in jurisdictions listed as tax havens 

or financial privacy jurisdictions and the amount of federal contract 

obligations these corporation have, if any, and 

 4

GAO, U.S. Multinational Corporations: Effective Tax Rates Are Correlated with Where 

Income Is Reported, GAO-08-950 (Washington, D.C.: Aug. 12, 2008), which includes

information for 17 foreign locations. For a GAO review of the business reasons for 

establishing a business in a specific jurisdiction, see GAO, Cayman Islands: Business and

Tax Advantages Attract U.S. Persons and Enforcement Challenges Exist, GAO-08-778 

(Washington, D.C.: July 24, 2008). 

5

GAO, International Taxation: Information on Federal Contractors With Offshore 

Subsidiaries, GAO-04-293 (Washington, D.C.: Feb. 2, 2004).

6

These characteristics include no or nominal taxes; lack of effective exchange of tax 

information with foreign tax authorities; lack of transparency in the operation of 

legislative, legal, or administrative provisions; no requirement for a substantive local 

presence; or self-promotion as an offshore financial center. 

7

These sources describe offshore financial centers as jurisdictions that have a high level of 

nonresident financial activity and that may have low or no taxes, light and flexible 

regulation, and a high level of client confidentially, and describe financial privacy 

jurisdictions as jurisdictions that have strict bank secrecy laws that persons can use to

shield their wealth from taxation in their home countries. 

Page 2 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
 

• determine how many of the 100 largest publicly traded U.S. federal 

contractors in terms of contract obligations have subsidiaries in 

jurisdictions listed as tax havens or financial privacy jurisdictions. 

The three sources we used for jurisdictions listed as tax havens or 

financial privacy jurisdictions are (1) the Organization for Economic Cooperation and Development’s (OECD) list of committed jurisdictions and

uncooperative tax havens,

8

 (2) a National Bureau of Economic Research 

(NBER) working paper9

 list of tax havens, and (3) a U.S. District Court 

order10 granting leave for the Internal Revenue Service (IRS) to serve a 

“John Doe” summons that included a list of offshore tax haven or financial 

privacy jurisdictions.11 We combined the jurisdictions on the OECD, 

NBER, and John Doe summons lists because we did not have a basis for 

excluding any of the identified jurisdictions, resulting in a list of 50 tax 

haven or financial privacy jurisdictions. 

We used the 2008 Fortune 500 list,12 data from USASpending.gov, the 

Federal Procurement Data System-Next Generation (FPDS-NG),13 and 

contractor’s Web sites to identify the 100 largest publicly traded U.S. 

corporations and U.S federal contractors and the amount of federal 

contract obligations. We assessed the reliability of USASpending.gov and 

FPDS-NG and determined that the data were sufficiently reliable for 

determining the general extent of federal contract obligations. We used the 

Securities and Exchange Commission’s (SEC) Electronic Data Gathering, 

Analysis, and Retrieval database to determine where corporations 

reported having significant subsidiaries. Our scope and methodology, 

including the basis for the list of 50 jurisdictions listed as tax havens or 

 8

OECD removes the Marshall Islands from its List of Unco-operative Tax Havens, 

August 7, 2007, which includes a link to 35 Jurisdictions Committed to Improving 

Transparency and Establishing Effective Exchange of Information in Tax Matters. 

9

Dhammika Dharmapala and James R. Hines, Jr., Which Countries Become Tax Havens? 

(National Bureau of Economic Research, Cambridge, Mass.: December 2006). 

10In the Matter of Tax Liabilities: of John Does, et al., No. 5:05-cv-04167-JW (N.D. Cal.

2006). 

11The court did not address whether these jurisdictions were in fact tax havens in its ruling. 

12We used the 2008 Fortune 500 list, which is based on revenues for 2007. The revenues

were for the corporations’ fiscal years, which ended on or before January 31, 2008. 

13USASpending.gov is a government Web site available to the public that provides

information about federal contracts. It utilizes data from FPDS-NG and aggregates 

subsidiaries and divisions by parent company using information provided by Dun and

Bradstreet. We used fiscal year 2007 contract obligations. 

Page 3 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
 

financial privacy jurisdictions, are described in greater detail in appendix 

I. 

Eighty-three of the 100 largest publicly traded U.S. corporations in terms 

of 2007 revenue reported having subsidiaries14 in jurisdictions listed as tax 

havens or financial privacy jurisdictions and 74 of the 83 had federal 

contracts in fiscal year 2007. For the 74 corporations, the amount of the 

federal contract obligations ranged from $12,000 to over $23 billion. 

Additional details about these corporations include the following: 

Results 

• Eighty-six of the 100 corporations had foreign subsidiaries and 14 did not.

Eighty-three of the 86 corporations had subsidiaries in locations other 

than jurisdictions listed as tax havens or financial privacy jurisdictions. 

• Four of the 83 corporations that had subsidiaries in jurisdictions listed as 

tax havens or financial privacy jurisdictions had more than 100 

subsidiaries in such jurisdictions. 

• For the 83 corporations with subsidiaries in jurisdictions listed as tax 

havens or financial privacy jurisdictions, the number of such subsidiaries 

ranged from 1 for nine corporations to a high of 427 for one corporation.

• Twelve corporations had more than 50 percent of their foreign

subsidiaries in jurisdictions listed as tax havens or financial privacy

jurisdictions. Three of these 12 only had one foreign subsidiary. 

• Corporations had subsidiaries in 36 of the 50 jurisdictions listed as tax 

havens or financial privacy jurisdictions. 

• Eight jurisdictions listed as tax havens or financial privacy jurisdictions 

had more than 100 corporate subsidiaries, ranging from 123 to 569. For the 

jurisdiction with 569 subsidiaries, 372 were owned by four corporations. 

• Thirty-four of the 100 corporations are also on the list of 100 largest 

publicly traded U.S. federal contractors. 

Sixty-three of the 100 largest publicly traded U.S. federal contractors in 

terms of fiscal year 2007 contract obligations reported having subsidiaries 

in jurisdictions listed as tax havens or financial privacy jurisdictions, 34 

did not, and 3 did not provide information about the locations of all of 

 14We used information filed with the SEC to determine where subsidiaries were located.

The SEC only requires public corporations to report significant subsidiaries. They may omit 

information on subsidiaries that, when considered in the aggregate, would not constitute 

significant subsidiaries, and on consolidated wholly owned multiple subsidiaries carrying 

on the same line of business (such as chain stores). Therefore, these corporations could

have additional subsidiaries not considered significant in jurisdictions listed as tax havens 

or financial privacy jurisdictions. For more information about the definition of significant 

subsidiaries, see app. I. 

Page 4 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
 

their subsidiaries. The following additional details about the federal 

contractors are based on the 97 contractors that provided complete 

information. 

• Seventy-two of the 97 federal contractors had foreign subsidiaries and 25

did not. Sixty-nine of the 72 contractors also had subsidiaries in locations 

other than jurisdictions listed as tax havens or financial privacy 

jurisdictions. 

• For the 63 federal contractors with subsidiaries in jurisdictions listed as 

tax havens or financial privacy jurisdictions, the number of such 

subsidiaries ranged from 1 for 11 contractors to a high of 83 for 1 

contractor. 

• Four federal contractors had more than 50 percent of their foreign 

subsidiaries in jurisdictions listed as tax havens or financial privacy

jurisdictions. Three of the four had all of their foreign subsidiaries in such

jurisdictions. 

• Federal contractors had subsidiaries in 34 of the 50 jurisdictions listed as 

tax havens or financial privacy jurisdictions. 

• Five of the jurisdictions listed as tax havens or financial privacy 

jurisdictions had more than 100 federal contractor subsidiaries, ranging 

from 111 to 156. 

• Thirty-four of the 100 federal contractors are also on the list of 100 largest 

publicly traded U.S. corporations. 

For a list of the 100 largest publicly traded U.S. corporations in terms of 

2007 revenues, the amount of their fiscal year 2007 federal contract 

obligations, the number of foreign subsidiaries, the number of foreign 

subsidiaries located in jurisdictions listed as tax havens or financial 

privacy jurisdictions, and the locations of those subsidiaries, see appendix 

II. For a list of the 100 largest publicly traded U.S. federal contractors in 

terms of fiscal year 2007 contract obligations, number of foreign 

subsidiaries, the number of foreign subsidiaries located in jurisdictions 

listed as tax havens or financial privacy jurisdictions, and the location of

those subsidiaries, see appendix III. 

The existence of a subsidiary in a jurisdiction listed as a tax haven or 

financial privacy jurisdiction does not signify that a corporation or 

contractor established that subsidiary for the purpose of reducing its tax

burden. We did not attempt to determine if corporations or contractors 

engaged in transactions with their subsidiaries in order to reduce their tax

burden. 

Page 5 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
 

Treasury’s Deputy Assistant Secretary for International Tax Affairs 

provided written comments on a draft of this report on December 9, 2008, 

and those comments are reprinted in appendix IV. He wrote that Treasury 

takes offshore tax evasion very seriously and has taken strong

administrative and regulatory steps to address the problem. However, the 

Deputy Assistant Secretary raised concerns about our use of a list of tax 

havens and financial privacy jurisdictions because, as we noted in the 

report, there is no agreed-upon definition of tax havens or list of 

jurisdictions. He added that we did indeed produce such a list by 

combining three lists prepared by others. He also stated that the lack of 

consensus results from the fact that determining which jurisdictions are 

tax havens may depend on whether the issue of interest concerns 

individual or corporate taxpayers. 

In order to respond to Congress’s interest in learning about the extent to

which U.S. corporations and federal contractors have subsidiaries in 

jurisdictions listed as tax havens or financial privacy jurisdictions, we 

needed a list of such jurisdictions. We combined three lists of jurisdictions 

listed as tax havens or financial privacy jurisdictions prepared by others. 

We also stated in our report that we did not develop our own definition of 

a tax haven or our own list of jurisdictions. However, even though there is 

no agreed-upon definition, we combined the three lists because the 

sources used similar characteristics to define and identify tax havens or 

financial privacy jurisdictions and there was substantial overlap between 

the countries on the lists. Of the 50 jurisdictions included in this report, 24 

are on all three lists, 14 are on two of the lists, and 12 are on one list. We 

did not exclude any of the identified jurisdictions because we did not have 

a basis for doing so. 

The Deputy Assistant Secretary specifically questioned our use of two of 

the three lists—the OECD list and the list of jurisdictions included in an 

IRS “John Doe” summons. The Deputy Assistant Secretary said that the 

majority of countries have committed to meeting OECD standards and 

many have signed tax information exchange agreements with the United 

States. He found it surprising that we used the lack of an updated list as 

the rationale for using what he characterized as the 2000 OECD list. We 

used an OECD list that was included in a May 3, 2007, written testimony by 

the Director, OECD Center for Tax Policy and Administration, before the 

Senate Finance Committee, which referred to the OECD 2000 list. We 

updated the May 2007 list based on information on OECD’s Web site. The 

Director of OECD’s Centre for Tax Policy and Administration

acknowledged in a letter to GAO that OECD and others have not provided 

a clear picture of which countries are making progress toward meeting 

Agency Comments 

and Our Evaluation 

Page 6 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
 

those commitments and which are not. Lacking an unambiguous 

identification of the countries making or not making progress, we included 

all of the countries on the updated OECD list because we could not 

determine which countries are currently meeting OECD standards. 

Regarding our use of the jurisdictions identified in IRS’s “John Doe” 

summons, the Deputy Assistant Secretary noted that the list of

jurisdictions in the summons was put together for the specific purpose of

seeking information about individuals who had signature authority over 

bank accounts or credit cards issued by financial institutions in those 

jurisdictions and was not intended to suggest a general list of jurisdictions 

that Treasury and IRS considered tax havens. He wrote that it was unclear

how the list of countries in the “John Doe” summons was relevant to our 

report because the problems addressed in our report and the summons are 

so different. We used the identified jurisdictions because, as pointed out in

appendix I, the declaration of an IRS agent in support of the summons, 

which was granted by a U.S. District Court, stated that the jurisdictions 

included in the summons “are all recognized as principal offshore tax 

haven or financial privacy jurisdictions by industry analysts and are 

actively marketed as such by promoters of offshore schemes.” 

Finally, the Deputy Assistant Secretary expressed concern that the list of 

jurisdictions in our report could be regarded as a blacklist and may be 

used as the basis for the imposition of sanctions or other negative 

measures. Our report provides information to Congress about the extent

to which U.S. corporations and federal contractors have subsidiaries in 

jurisdictions listed as tax havens or financial privacy jurisdictions. It does 

not make recommendations about changes to U.S. tax, economic, or 

foreign policy. As noted in the report, corporations have subsidiaries in 

such jurisdictions for a variety of business reasons, including reasons 

related to taxes. 

The Commissioner of Internal Revenue provided written comments on a 

draft of this report in a December 11, 2008, letter which is reprinted in 

appendix V. The Commissioner wrote that international tax issues are 

some of the most complex that IRS confronts and that he has made these a 

top priority in addition to IRS’s continued efforts to combat offshore tax 

evasion. In addition, he welcomed the support provided by independent

research and analysis that complements IRS’s initiatives in this area and 

expressed his appreciation of our work on this report and this topic in 

general. The SEC provided oral comments of a technical nature that were 

incorporated into our report. 

Page 7 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
 

As agreed with your offices, unless you publicly announce its contents 

earlier, we plan no further distribution of this report until 30 days after its 

date. At that time, we will send copies of this report to the Secretary of the 

Treasury, the Commissioner of Internal Revenue, the Chairman of the 

Securities and Exchange Commission, and other interested parties. The 

report also will be available at no charge on GAO’s Web site at 

http://www.gao.gov. 

If any of your staff have any questions, please contact me at (202) 512-9110

or whitej@gao.gov. Contact points for our Offices of Congressional 

Relations and Public Affairs may be found on the last page of this report. 

James R. White 

Key contributors to this report are listed in appendix VI. 

Director, Tax Issues 

Strategic Issues Team

Page 8 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix I: 

Methodology 

Objectives, Scope, and 

Page 9 GAO-09-157

Appendix I: Objectives, Scope, and 

Methodology 

We had two objectives. Our first objective was to determine how many of 

the 100 largest publicly traded U.S. corporations in terms of revenue have

subsidiaries in jurisdictions listed as tax havens or financial privacy

jurisdictions and the amount of federal contract obligations these 

corporations have, if any. Our second objective was to determine how 

many of the 100 largest publicly traded U.S. federal contractors in terms of 

contract obligations have subsidiaries in jurisdictions listed as tax havens

or financial privacy jurisdictions. We did not determine if corporations or 

contractors with subsidiaries in jurisdictions listed as tax havens or 

financial privacy jurisdictions engaged in transactions or took other 

actions with regard to their subsidiaries in order to reduce their tax 

burden. Subsidiaries may be established in listed jurisdictions for a variety

of nontax business reasons. For both objectives, we reviewed and 

analyzed relevant documents and interviewed Department of the Treasury, 

Internal Revenue Service (IRS), and Securities and Exchange Commission 

(SEC) officials. 

To address both objectives, we needed to identify jurisdictions that have 

been listed as tax havens or financial privacy jurisdictions. For this report 

as in our 2004 report on federal contractors with offshore subsidiaries, we 

did not attempt to develop a list of such jurisdictions.1

 Instead, to find 

sources that may identify such jurisdictions, we searched numerous 

governmental, international, and academic Internet sites using various key 

words or phrases. Examples of sites searched include those of the 

Department of the Treasury, IRS, the Congressional Budget Office, the 

Congressional Research Service, the Organization for Economic Cooperation and Development (OECD),2

 the International Monetary Fund 

(IMF), the Financial Stability Forum (FSF),3

 the World Bank, EconLit, F&S 

Index (a global index of financial publications), Tax Notes, and sites that 

include excerpts from legislative documents, such as bills or committee 

reports. Examples of key words or phrases searched include tax havens, 

Identifying Jurisdictions 

Listed as Tax Havens or 

Financial Privacy 

Jurisdictions 

 1

GAO, International Taxation: Information on Federal Contractors With Offshore 

Subsidiaries, GAO-04-293 (Washington, D.C.: Feb. 2, 2004).

2

OECD is a forum where the governments of 30 market democracies work together to

address economic, social, and governance challenges of globalization. 

3

The FSF was convened in April 1999 at the initiative of the G7 Finance Ministers and 

Central Bank Governors in order to promote international financial stability, improve the

functioning of financial markets, and reduce the tendency for financial shocks to propagate

from country to country, thus destabilizing the world economy. 

U.S. Corporations with Foreign Subsidiaries
Appendix I: Objectives, Scope, and 

Methodology 

offshore tax havens, secrecy jurisdictions, offshore secrecy jurisdictions, 

and offshore financial centers. Our review of these sites did not find an 

agreed-upon definition for a tax haven or an agreed-upon list of 

jurisdictions that should be considered tax havens. However, the sources 

we reviewed used similar characteristics to define and identify tax havens, 

including no or nominal taxes; lack of effective exchange of tax 

information with foreign tax authorities; lack of transparency in the 

operation of legislative, legal, or administrative provisions; no requirement 

for a substantive local presence; and self-promotion as an offshore 

financial center. In addition, a few sources used characteristics similar to 

those used in describing tax havens to describe offshore financial centers4

or financial privacy jurisdictions.5

 For brevity purposes, we referred to the 

jurisdictions included in our report as jurisdictions listed as tax havens or 

financial privacy jurisdictions. 

Based on our research, we identified the following three lists of 

jurisdictions considered to be tax havens or financial privacy 

jurisdictions.6

• OECD’s list of committed jurisdictions and uncooperative tax havens.7

• A National Bureau of Economic Research (NBER) working paper,8 which 

included a list of tax havens that was based on research summarized in an 

article in The Quarterly Journal of Economics.9

 

 4

Offshore financial centers are generally described as jurisdictions that have a high level of 

nonresident financial activity, and may have characteristics including low or no taxes, light

and flexible regulation, and a high level of client confidentiality. 

5

Financial privacy jurisdictions are generally described as jurisdictions that have strict 

bank secrecy laws that persons can use to shield their wealth from taxation in their home 

countries. 

6

In addition, the IMF had a list of jurisdictions that were offshore financial centers. This list 

was based in part on work done by the FSF. However, IMF is no longer maintaining a list of 

offshore financial centers because it believes globalization is blurring the distinction 

between offshore financial centers and other financially active jurisdictions and there are 

no agreed-upon objective criteria for defining offshore financial centers. 

7

OECD removes the Marshall Islands from its List of Unco-operative Tax Havens, 

August 7, 2007, which includes a link to 35 Jurisdictions Committed to Improving 

Transparency and Establishing Effective Exchange of Information in Tax Matters. 

8

Dhammika Dharmapala and James R. Hines, Jr., Which Countries Become Tax Havens? 

(National Bureau of Economic Research, Cambridge, Mass.: December 2006). 

9

James R. Hines, Jr. and Eric M. Rice, “Fiscal Paradise: Foreign Tax Havens and American 

Business,” The Quarterly Journal of Economics, vol. 109, no. 1 (1994): 149-182. 

Page 10 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix I: Objectives, Scope, and 

Methodology 

• A U.S. District Court order granting leave for IRS to serve a “John Doe” 

summons,10 which included a list of jurisdictions that are recognized as 

offshore tax haven or financial privacy jurisdictions11 by industry analysts 

and are actively promoted as such by promoters of offshore schemes.12

We combined the jurisdictions on the three lists because we did not have a 

basis for excluding any of the identified jurisdictions. This resulted in a list 

of 50 jurisdictions listed as tax havens or financial privacy jurisdictions. 

The 50 jurisdictions as well as the sources for the jurisdictions are shown 

in table 1. Of the 50 jurisdictions, 24 are on all three lists, 14 are on two of 

the lists, and 12 are on one list. 

 10A John Doe summons is a third-party summons that does not identify the person with 

respect to whose tax liability the summons is issued and may be served only after a court 

proceeding. A third-party summons is a summons requesting information on a person or

persons other than the recipient of the summons. To obtain a John Doe summons, the 

United States must establish that (1) the summons relates to the investigation of a 

particular person or ascertainable group or class of persons whose identity is unknown, 

(2) there is a reasonable basis for believing that such person or group or class of persons

may fail or may have failed to comply with any provision of any internal revenue law, and

(3) the information sought to be obtained from the examination of the records or testimony

and the identity of the John Doe(s) is not readily available from other sources. 26 U.S.C. § 

7609(f). 

11The court did not address whether these jurisdictions were in fact tax havens in its ruling. 

12According to an IRS Office of Research official, the office used a list of tax havens in a

research project. The list was developed many years ago and does not include any

jurisdictions that are not included in the John Doe summons.

Page 11 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix I: Objectives, Scope, and 

Methodology 

Table 1: Jurisdictions Listed as Tax Havens or Financial Privacy Jurisdictions and

the Sources of Those Jurisdictions 

Jurisdiction OECD NBER

U.S. District Court order granting

leave for IRS to serve a “John

Doe” summons

Andorra XaX

Anguilla X X X

Antigua and Barbuda X X Xb

Aruba X Xb

Bahamas X X Xb

Bahrain X X

Barbados X Xb

Belize X X X

Bermuda X X Xb, c

British Virgin Islands X X Xd

Cayman Islands X X Xb

Cook Islands X X X 

Costa Rica Xb

Cyprus X X Xc

Dominica X X Xb

Gibraltar X X X

Grenada X X Xb

Guernsey X XdXb, e

Hong Kong X X 

Ireland X

Isle of Man X X Xb

Jersey X XdXb

Jordan X

Latvia Xc

Lebanon X

Liberia X X

Liechtenstein XaX X

Luxembourg X Xc

Macao X

Maldives X

Malta X X X

Marshall Islands X X 

Mauritius X

Page 12 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix I: Objectives, Scope, and 

Methodology 

Jurisdiction OECD NBER

U.S. District Court order granting

leave for IRS to serve a “John

Doe” summons

Monaco XaX

Montserrat X X

Nauru X X

Netherlands Antilles X X Xb

Niue X

Panama X X X

Samoa X X

San Marino X 

Seychelles X

Singapore X X

St. Kitts and Nevis X X X 

St. Lucia X X Xf

St. Vincent and the Grenadines X X X 

Switzerland X Xc

Turks and Caicos Islands X X X 

U.S. Virgin Islands X 

Vanuatu X X X

Sources: OECD, NBER, and John Doe summons. 

a

These are uncooperative tax havens; the remaining are committed jurisdictions. These terms are 

explained in the following paragraph. 

b

A Tax Information Exchange Agreement (TIEA) is in force between the United States and this 

jurisdiction. 

c

A double tax treaty is in force with an exchange of information provision. For Switzerland, the treaty 

provides that the competent authorities of the contracting states shall exchange such information as 

is necessary “for the prevention of tax fraud or the like.” 

d

NBER’s list included the Channel Islands. Jersey and Guernsey are part of the Channel Islands. The 

two other sources we used to identify tax havens listed Jersey and Guernsey as two separate tax 

havens and did not include the Channel Islands on their lists of tax havens. To be consistent, we are 

including Jersey and Guernsey as tax havens on the bureau’s list rather than the Channel Islands. 

e

The John Doe summons lists Guernsey/Sark/Alderney. OECD only included Guernsey. Since Sark 

and Alderney are part of the Bailiwick of Guernsey, to be consistent, we are only including Guernsey

on our list of tax havens. 

f

The TIEA signed by the United States and St. Lucia on January 30, 1987, is not in effect within the 

meaning of section 274(h)(6)(A)(i) of the Internal Revenue Code because the government of St. Lucia 

has not enacted legislation to implement the agreement. 

As of February 2008, OECD lists 38 jurisdictions—35 that have made 

commitments to cooperate with OECD in addressing issues related to 

transparency and the effective exchange of information and 3 that have 

Organization for Economic Cooperation and Development 

Page 13 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix I: Objectives, Scope, and 

Methodology 

not made such commitments.13 OECD refers to the 35 as committed 

jurisdictions and the remaining 3 as uncooperative tax havens. Although 

OECD does not provide a unique definition of the term tax haven, OECD 

has established a set of criteria to characterize a tax haven. Specifically, 

OECD stipulates four major features of a tax haven: (1) no or nominal 

income tax; (2) rules that prevent the effective exchange of information 

with foreign tax authorities; (3) a lack of transparency in the operation of 

legislative, legal, or administrative provisions; and (4) the absence of a 

requirement for a substantive local presence. In general, OECD classifies a 

country as a tax haven if it meets the criterion of no or nominal income 

tax, and at least one of the other criteria. Most of the committed 

jurisdictions agreed to cooperate with OECD in addressing “harmful tax 

practices” by December 31, 2005. However, OECD reported in October 

2007 that some jurisdictions that committed to implementing standards on 

transparency and the effective exchange of information had failed to do 

so, although OECD did not specify which or how many jurisdictions had 

not made progress. As a result, we included all 38 jurisdictions in our 

review. 

An NBER December 2006 working paper14 that attempts to determine 

which jurisdictions become tax havens uses as its basic definition the list 

of 41 countries and territories identified as tax havens by Hines and Rice 

in a 1994 article in The Quarterly Journal of Economics.

15 This list is 

based on the coexistence of low business tax rates in a jurisdiction in 1982 

and its identification as a tax haven by multiple authoritative sources. As 

explained below, this resulted in a list of 40 tax havens that we used in our 

review. 

National Bureau of Economic 

Research 

 13OECD does not systematically review this list to determine if jurisdictions should be 

removed from it. 

14Dharmapala and Hines, Which Countries Become Tax Havens? NBER, founded in 1920, 

is a private, nonprofit, nonpartisan research organization dedicated to promoting a greater 

understanding of how the economy works. NBER is committed to undertaking and

disseminating unbiased economic research among public policymakers, business

professionals, and the academic community and is the nation’s leading nonprofit economic 

research organization. 

15Hines and Rice, “Fiscal Paradise: Foreign Tax Havens and American Business.” The 

Quarterly Journal of Economics is the oldest professional journal of economics in the

English language. Edited at Harvard University’s Department of Economics, it covers all 

aspects of the field—from the journal’s traditional emphasis on microtheory to both

empirical and theoretical macroeconomics. 

Page 14 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix I: Objectives, Scope, and 

Methodology 

Although The Quarterly Journal of Economics article identifies 41 

countries as tax havens, the NBER study revised this list to include 39 

countries. First, The Quarterly Journal of Economics article included the

United Kingdom Caribbean Islands and St. Martin. The NBER study 

deleted the United Kingdom Caribbean Islands from the list because the 

United Kingdom Caribbean Islands is a general term used by the Bureau of 

Economic Analysis for British dependencies in the Caribbean, and most of 

these dependencies are included as separate tax havens on the list 

(Anguilla, Montserrat, the Cayman Islands, and the Turks and Caicos 

Islands). Second, the NBER study also deleted St. Martin from the list 

because it is part of the Netherlands Antilles and the Netherlands Antilles 

is already included on the list. 

The NBER study and The Quarterly Journal of Economics article 

included the Channel Islands on the list of tax havens. Jersey and 

Guernsey are part of the Channel Islands. The other sources we used to 

identify tax havens listed Jersey and Guernsey as two separate tax havens 

and did not include the Channel Islands on their lists of tax havens or 

financial privacy jurisdictions. To be consistent, we are including Jersey 

and Guernsey as tax havens rather than the Channel Islands. When this 

criterion is applied, the NBER study includes 40 tax havens.16

Per The Quarterly Journal of Economics article, tax havens are often 

defined as locations with the following four attributes: (1) low corporate 

or personal tax rates, (2) legislation that supports banking and business 

secrecy, (3) advanced communication facilities, and (4) self-promotion as 

an offshore financial center. The Quarterly Journal of Economics list of 

tax havens is a combination of the following 

• The authors started with a list of 32 tax haven countries that Glautier and 

Bassinger reported in 1987 were in the Internal Revenue Manual. They 

deleted 3 countries in which the foreign corporate tax paid by U.S. 

companies was greater than 20 percent of pretax income resulting in a list 

of 29 tax haven countries. 

• Next, the authors used Andre Beauchamp’s17 list of tax haven countries. 

This list included all of the IRS-identified countries plus 15 others. The 

 16After deleting the Channel Islands from the list of 39 tax havens and adding Jersey and 

Guernsey, the resulting total is 40. 

17Andre Beauchamp, Guide Mondial des Paradis Fiscaux (Paris: Editions Grasset & 

Fasqualle, 1983). 

Page 15 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix I: Objectives, Scope, and 

Methodology 

authors added the Beauchamp countries, which had an average tax rate

lower than 10 percent for U.S. companies. This resulted in adding 7 

countries to the list. 

• They applied the same criteria (average tax rate lower than 10 percent for 

U.S. companies) to the countries discussed in the Economist Intelligence 

Unit’s18 tax haven volume developed by Caroline Doggart19 in 1983 that 

they applied to the countries included in the Beauchamp study. This 

resulted in adding five countries to the list. 

This resulted in a list of 41 tax havens. As previously explained, to be

consistent with other sources we used to identify tax havens, there are 40

tax havens on this list. 

On October 14, 2005, the United States filed in the U.S. District Court for 

the Northern District of California an ex parte petition for leave to serve a 

“John Doe” summons upon PayPal, Inc. and its affiliates and subsidiaries 

pursuant to sections 7402(a), 7609(f), and 7609(h) of the Internal Revenue

Code,20 and the court issued an order granting leave to serve the John Doe 

summons in February 2006.21A John Doe summons is a third-party 

summons22 that does not identify the person with respect to whose tax 

liability the summons is issued and may be served only after a court 

proceeding.

23 The summons was for information on U.S. taxpayers who, 

during the years ended December 31, 1999, through December 31, 2004, 

had signature authority over bank accounts at or over MasterCard, VISA, 

John Doe Summons 

 18The Economist Intelligence Unit is a global research and advisory firm whose mission is 

to provide executives with authoritative analysis and forecasts to make informed global 

decisions. 

19Caroline Doggart, Tax Havens and Their Uses (London: Economist Intelligence Unit, 

1983). 

20In the Matter of the Tax Liabilities of John Does, No. 5:05-cv-04167-PVT (N.D. Cal. 2005).

21In the Matter of Tax Liabilities of John Does, et al., No. 5:05-cv-04167-JW (N.D. Cal.

2006). 

22A third-party summons is a summons requesting information on a person or persons other

than the recipient of the summons. 

23To obtain a John Doe summons, IRS must establish that (1) the summons relates to the 

investigation of a particular person or ascertainable group or class of persons whose 

identity is unknown, (2) there is a reasonable basis for believing that such person or group 

or class of persons may fail or may have failed to comply with any provision of any internal

revenue law, and (3) the information sought to be obtained from the examination of the 

records or testimony and the identity of the John Doe(s) is not readily available from other

sources. 26 U.S.C. § 7609(f). 

Page 16 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix I: Objectives, Scope, and 

Methodology 

or American Express cards issued by, through, or on behalf of banks or 

other financial institutions in 34 jurisdictions. 

Supporting the petition was a declaration of an IRS revenue agent.24 The 

IRS agent stated that IRS was conducting an investigation to determine the 

correct federal income tax liabilities, for the years ended December 31, 

1999, through December 31, 2004, of U.S. taxpayers who had signature 

authority over bank accounts or other MasterCard, VISA, or American 

Express cards issued by, through, or on behalf of banks or other financial

institutions in the same 34 jurisdictions. Further, in the declaration the 

agent states the following: 

“Based upon my experience and information received from other investigations, it is likely 

that a number of the persons who have signature authority over bank accounts at or over

American Express, MasterCard, or VISA payment cards issued by, through, or for banks or 

other financial institutions in the jurisdictions identified ... may have been under-reporting

income, evading income taxes, or otherwise violating the internal revenue laws of the 

United States.”25

In this declaration, the IRS revenue agent stated that the 34 jurisdictions 

listed on the John Doe summons to PayPal “are widely known as places 

where, because of strict bank secrecy laws and devices such as 

International Business Corporations, trusts and other subterfuges, persons 

can shield their wealth from taxation in their home countries. These 

jurisdictions are all recognized as principal offshore tax haven or financial 

privacy jurisdictions by industry analysts and are actively marketed as 

such by promoters of offshore schemes.”26 The declaration explains that 

these jurisdictions were selected “on the reasonable belief that United 

States taxpayers have failed or may have failed to comply with provisions 

of the internal revenue laws through the use of American Express, 

MasterCard, or VISA payment cards issued by, through, or on behalf of 

banks and other financial institutions in those jurisdictions.”27

 24Declaration of Barbara Kallenberg, In the Matter of the Tax Liabilities of John Does, No.

5:05-cv-04167-PVT (N.D. Cal. 2005). 

25Id. at 4-5. 

26Id. at 48. 

27Id. at 48-49. 

Page 17 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix I: Objectives, Scope, and 

Methodology 

For the first objective, we used the Fortune 500 list to identify the 100 

largest publicly traded U.S. corporations in terms of revenue for 2007.28 We 

used data from USASpending.gov29 to determine if these corporations had 

2007 fiscal year federal contract obligations and, if so, the amount of those 

obligations. For the second objective, we used USASpending.gov to 

identify the largest federal contractors based on fiscal year 2007 

obligations and used information from the contractors’ Web sites and the 

Fortune 500 list to determine if they were publicly traded U.S.

corporations. Based on this information, we developed a list of the 100 

largest publicly traded U.S. federal contractors. 

USASpending.gov utilizes data from the Federal Procurement Data 

System-Next Generation (FPDS-NG) and aggregates subsidiaries and 

divisions by parent company using information provided by Dun and 

Bradstreet. To assess the reliability of USASpending.gov and FPDS-NG 

data, we reviewed documentation about the data and systems that 

produced them, including the FPDS-NG data element dictionary, data 

validation rules, and certification process. Based on this, we determined 

that the data were sufficiently reliable for the purpose of determining the 

general extent of federal contract obligations. However, because of 

situations in which corporations may participate in other activities, such 

as joint ventures; limited information on some corporations; and the 

constantly changing circumstances of corporations, their holdings, and 

their contracts, we faced challenges in developing a list of the largest 

federal contractors and determining the total obligations of those 

contracts. As a result, we developed the following criteria to develop the 

list of the 100 largest publicly traded U.S. federal contractors and to 

determine the amounts of contract obligations:

Identifying the Largest 

Corporations and Federal 

Contractors and Their 

Subsidiaries in 

Jurisdictions Listed as Tax 

Havens or Financial 

Privacy Jurisdictions 

• First, we excluded subsidiaries and joint ventures because they are not 

publicly traded.30

• Second, if we could not determine if a contractor was a publicly traded

U.S. corporation, we did not include the contractor on our list. In these 

cases we often identified news articles or information from the 

 28We used the 2008 Fortune 500 list, which is based on revenues for 2007. The revenues

were for the corporations’ fiscal years that ended on or before January 31, 2008. 

29USASpending.gov is a government Web site available to the public that provides

information about federal contracts. 

30Subsidiaries are owned by corporations that may or may not be publicly traded and joint 

ventures are owned by two or more corporations that may or may not be publicly traded.

Page 18 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix I: Objectives, Scope, and 

Methodology 

contractor’s Web sites that indicated that the contractor was not publicly 

traded or was not a U.S. company, such as only finding information about 

the contractor in a foreign language.

• Third, in determining the amount of obligations, if a subsidiary of a 

contractor was listed, we did not add the dollar amount of the subsidiary’s 

contract to the parent’s contract, and if a contractor was listed twice, we 

used the dollar amount only from the first listing of the contractor and did 

not add the contract amount(s) from any other listings for that contractor. 

We did not add subsidiary contracts to parents’ contracts or add multiple 

listings of the same contractor because if we did so, then to ensure that we 

used comparable data for other contractors, we would have needed to 

review the entire list of federal contractors and conduct additional 

research for each contractor to identify other subsidiaries or multiple 

listings. Since the federal contract amount is secondary to the main 

purpose of our review—to identify the extent of subsidiaries in 

jurisdictions that may be listed as tax havens or financial privacy 

jurisdictions—we determined that not reviewing the entire list of federal 

contractors was an acceptable limitation for our review. 

Using these criteria likely resulted in lower estimates of contract 

obligations for some federal contractors as well as the contract obligations 

for some of the largest corporations. 

To address both objectives, we used Form 10-K31 and Exhibit 21,32 which 

are included in the SEC’s Electronic Data Gathering, Analysis, and 

Retrieval database (EDGAR), to determine the locations of corporations’ 

and contractors’ subsidiaries based on their latest filings with the SEC at 

the time of our review. Since the principal executive officer(s), the 

principal financial officer(s), the controller or principal accounting officer, 

and at least the majority of the board of directors or persons with similar 

functions must sign the form filed with the SEC that includes the 

subsidiaries, we did not take additional steps to verify the accuracy of 

information found in EDGAR. Also, since the SEC only requires public 

corporations to report their significant subsidiaries, we were only able to

identify the subset of corporate subsidiaries meeting the definition of 

significant subsidiary. Within Exhibit 21, public corporations may omit 

 31Form 10-K is used for the annual reports or transition reports that corporations file with 

the SEC according to the Securities Exchange Act of 1934. 15 U.S.C. §§ 78m, 78o(d); 17

C.F.R. § 249.310. 

32In Exhibit 21, public corporations are required to list their subsidiaries and the names 

under which they do business and the state or jurisdiction of incorporation or organization. 

Page 19 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix I: Objectives, Scope, and 

Methodology 

information on those subsidiaries that do not constitute significant 

subsidiaries when considered in the aggregate. The SEC considers a 

subsidiary to be significant if (1) the parent corporation’s and its other 

subsidiaries’ investments in and advances to the subsidiary exceed 10 

percent of the consolidated total assets of the parent corporation and its 

subsidiaries, (2) the parent corporation’s and its other subsidiaries’ 

proportionate share of the total assets (after intercompany eliminations) 

of the subsidiary exceeds 10 percent of the consolidated total assets of the 

parent corporation and its subsidiaries, or (3) the parent corporation and 

its other subsidiaries’ equity in the income from continuing operations33

exceeds 10 percent of the consolidated income from continuing operations 

of the parent corporation and its subsidiaries. Corporations may also omit 

information on consolidated wholly owned multiple subsidiaries carrying 

on the same line of business (such as chain stores). Since the SEC only 

requires public corporations to report significant subsidiaries, the number 

of subsidiaries in jurisdictions listed as tax havens or financial privacy 

jurisdictions for each corporation or federal contractor may be

understated in this report. 

 33In this case, the SEC defines such income as income from continuing operations before 

income taxes, extraordinary items, and the cumulative effect of a change in accounting 

principle. 

Page 20 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix II: The 100 Largest Publicly Traded 

U.S. Corporations 

Corporation 

Rank by

revenue

2007 Revenue

(dollars in 

millions) 

Federal contract 

obligations for

fiscal year 2007 

(dollars in thousands)

a

Number of foreign

subsidiaries 

Number and location(s) of

subsidiaries in jurisdictions 

listed as tax havens or financial 

privacy jurisdictions

3M 94 $24,462 $31,275 62 9

Bermuda (1)

Hong Kong (1)

Luxembourg (2)

Singapore (3)

Switzerland (2)

Abbott Laboratories 91 25,914 66,126 168 36

Bahamas (2)

Barbados (1)

Bermuda (5)

Costa Rica (1)

Grenada (1)

Hong Kong (1)

Ireland (13)

Latvia (1)

Lebanon (1)

Panama (2)

Singapore (2)

Switzerland (5)

Virgin Islands (1)

b

Aetna 83 27,600 192 14 8

Bermuda (4)

Cayman Islands (1)

Hong Kong (2)

Ireland (1)

Alcoa 79 30,748 80,235 31 4

Hong Kong (1)

Luxembourg (2)

Switzerland (1)

Allstate 63 36,769 0 7 1

Bermuda (1)

Appendix II: The 100 Largest Publicly Traded 

U.S. Corporations 

Page 21 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix II: The 100 Largest Publicly Traded 

U.S. Corporations 

Corporation 

Rank by

revenue

2007 Revenue

(dollars in 

millions) 

Federal contract 

obligations for

fiscal year 2007 

(dollars in thousands)

a

Number of foreign

subsidiaries 

Number and location(s) of

subsidiaries in jurisdictions 

listed as tax havens or financial 

privacy jurisdictions

Altria Group 60 38,051 0 163 38

British Virgin Islands (3)

Cayman Islands (1)

Costa Rica (2)

Hong Kong (1)

Ireland (2)

Latvia (1)

Luxembourg (1)

Netherlands Antilles (1)

Panama (2)

Singapore (3)

Switzerland (21)

American Express 74 32,316 355 165 39

Bahrain (2)

British Virgin Islands (2)

Cayman Islands (9)

Guernsey (6)

Hong Kong (4)

Jersey (4)

Luxembourg (3)

Netherlands Antilles (2)

Panama (1)

Singapore (2)

Switzerland (4)

American 

International Group 

13 110,064 598 88 18

Bahrain (2)

Bermuda (5)

Hong Kong (3)

Ireland (3)

Luxembourg (1)

Panama (1)

Switzerland (3)

AmerisourceBergen

Corporation 

28 66,074 1,469,378 0 0

Apple 97 24,006 2,221 1 1

Ireland (1)

Archer-DanielsMidland Company 51 44,018 197,488 6 3

Cayman Islands (2)

Ireland (1)

Page 22 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix II: The 100 Largest Publicly Traded 

U.S. Corporations 

Corporation 

Rank by

revenue

2007 Revenue

(dollars in 

millions) 

Federal contract 

obligations for

fiscal year 2007 

(dollars in thousands)

a

Number of foreign

subsidiaries 

Number and location(s) of

subsidiaries in jurisdictions 

listed as tax havens or financial 

privacy jurisdictions

AT&T, Inc. 10 118,928 519,233 0 0 

Bank of America 

Corporation 

9 119,190 13,763 311 115

Bahamas (3)

Bermuda (2)

Cayman Islands (59)

Gibraltar (2)

Hong Kong (8)

Ireland (14)

Jersey (3)

Luxembourg (15)

Mauritius (3)

Singapore (5)

U.S. Virgin Islands (1)

Berkshire 

Hathaway, Inc. 

11 118,245 235,394 27 1

Ireland (1)

Best Buy 65 35,934 1,885 35 13

Bermuda (2)

Hong Kong (2)

Luxembourg (1)

Mauritius (7)

Turks and Caicos Islands (1)

The Boeing 

Company 

27 66,387 23,312,965 135 38

Bermuda (6)

Cayman Islands (1)

Gibraltar (2)

Hong Kong (4)

Ireland (4)

Netherlands Antilles (2)

Singapore (3)

U.S. Virgin Islands (16)

Page 23 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix II: The 100 Largest Publicly Traded 

U.S. Corporations 

Corporation 

Rank by

revenue

2007 Revenue

(dollars in 

millions) 

Federal contract 

obligations for

fiscal year 2007 

(dollars in thousands)

a

Number of foreign

subsidiaries 

Number and location(s) of

subsidiaries in jurisdictions 

listed as tax havens or financial 

privacy jurisdictions

Cardinal Health, 

Inc. 

19 88,364 1,039,243 135 23

Barbados (1)

Bermuda (2)

British Virgin Islands (1)

Cayman Islands (1)

Hong Kong (1)

Ireland (5)

Luxembourg (3)

Malta (1)

Mauritius (1)

Singapore (3)

Switzerland (4)

Caterpillar, Inc. 49 44,958 171,485 329 49

Barbados (1)

Bermuda (13)

Costa Rica (1)

Guernsey (1)

Hong Kong (3)

Ireland (2)

Luxembourg (3)

Mauritius (1)

Panama (3)

Singapore (8)

Switzerland (13)

Chevron 3 210,783 98,418 45 23

Bahamas (5)

Bermuda (16)

Liberia (1)

Singapore (1)

Page 24 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix II: The 100 Largest Publicly Traded 

U.S. Corporations 

Corporation 

Rank by

revenue

2007 Revenue

(dollars in 

millions) 

Federal contract 

obligations for

fiscal year 2007 

(dollars in thousands)

a

Number of foreign

subsidiaries 

Number and location(s) of

subsidiaries in jurisdictions 

listed as tax havens or financial 

privacy jurisdictions

Cisco Systems 70 34,922 4,063 201 38

Barbados (1)

Bermuda (7)

Costa Rica (1)

Cyprus (1)

Hong Kong (5)

Ireland (8)

Jordan (1)

Latvia (1)

Luxembourg (2)

Mauritius (2)

Panama (1)

Singapore (6)

Switzerland (2)

Citigroup 8 159,229 3,122 1,240 427

Aruba (1)

Bahamas (16)

Bahrain (1)

Barbados (2)

Bermuda (19)

British Virgin Islands (35)

Cayman Islands (90)

Channel Islands (12)

Costa Rica (19)

Gibraltar (1)

Guernsey (1)

Hong Kong (40)

Ireland (16)

Isle of Man (1)

Jersey (21)

Luxembourg (91)

Macao (1)

Mauritius (15)

Panama (17)

St. Kitts and Nevis (1)

Singapore (18)

Switzerland (8)

Turks and Caicos Islands (1)

Page 25 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix II: The 100 Largest Publicly Traded 

U.S. Corporations 

Corporation 

Rank by

revenue

2007 Revenue

(dollars in 

millions) 

Federal contract 

obligations for

fiscal year 2007 

(dollars in thousands)

a

Number of foreign

subsidiaries 

Number and location(s) of

subsidiaries in jurisdictions 

listed as tax havens or financial 

privacy jurisdictions

Coca–Cola 81 28,857 29,942 72 8

British Virgin Islands (1)

Cayman Islands (2)

Costa Rica (1)

Hong Kong (1)

Ireland (1)

Singapore (1)

Switzerland (1)

Comcast 78 30,895 3,118 29 3

Hong Kong (1)

Netherlands Antilles (1)

Switzerland (1)

ConocoPhillips 5 178,558 267,206 125 44

Bahamas (2)

Bermuda (17)

British Virgin Islands (2)

Cayman Islands (9)

Ireland (3)

Liberia (5)

Luxembourg (2)

Marshall Islands (1)

Singapore (1)

Switzerland (2)

Costco Wholesale 29 64,400 12 3 1

Bermuda (1)

Countrywide 

Financial 

98 23,442 0 20 7

Cayman Islands (1)

Costa Rica (1)

Guernsey (2)

Hong Kong (1)

Mauritius (1)

Singapore (1)

CVS Caremark 24 76,330 971 0 0

Deere 96 24,082 29,428 32 3

Luxembourg (2)

Switzerland (1)

Page 26 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix II: The 100 Largest Publicly Traded 

U.S. Corporations 

Corporation 

Rank by

revenue

2007 Revenue

(dollars in 

millions) 

Federal contract 

obligations for

fiscal year 2007 

(dollars in thousands)

a

Number of foreign

subsidiaries 

Number and location(s) of

subsidiaries in jurisdictions 

listed as tax havens or financial 

privacy jurisdictions

Dell, Inc. 33 61,133 1,132,476 158 29

Bahrain (1)

Barbados (1)

Cayman Islands (4)

Costa Rica (2)

Hong Kong (1)

Ireland (10)

Lebanon (1)

Luxembourg (1)

Panama (1)

Singapore (5)

Switzerland (2)

Delphi 88 26,160 1,650 141 9

Ireland (1)

Luxembourg (3)

Singapore (3)

Virgin Islands (2)

b

Dow Chemical 41 53,513 10,180 317 35

Bahrain (1)

Barbados (3)

Bermuda (3)

Costa Rica (1)

Hong Kong (5)

Ireland (3)

Luxembourg (3)

Mauritius (2)

Singapore (6)

Switzerland (7)

Virgin Islands (1)

b

DuPont 80 30,653 3,386 44 9

Bermuda (2)

Hong Kong (1)

Luxembourg (2)

Singapore (1)

Switzerland (3)

Enterprise GP 

Holdings 

86 26,714 0 1 0

Page 27 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix II: The 100 Largest Publicly Traded 

U.S. Corporations 

Corporation 

Rank by

revenue

2007 Revenue

(dollars in 

millions) 

Federal contract 

obligations for

fiscal year 2007 

(dollars in thousands)

a

Number of foreign

subsidiaries 

Number and location(s) of

subsidiaries in jurisdictions 

listed as tax havens or financial 

privacy jurisdictions

Exxon Mobil 

Corporation 

2 372,824 949,152 122 32

Bahamas (18)

Bermuda (1)

Cayman Islands (3)

Hong Kong (3)

Ireland (1)

Luxembourg (2)

Singapore (3)

Switzerland (1)

Fannie Mae 52 43,355 0 0 0 

FedEx 67 35,214 59,453 101 21

Antigua (1)

Bahamas (1)

Barbados (1)

Bermuda (1)

Cayman Islands (3)

Costa Rica (1)

Grenada (1)

Hong Kong (2)

Ireland (3)

Netherlands Antilles (2)

Singapore (1)

St. Kitts (1)

St. Lucia (1)

Turks and Caicos Islands (1)

U.S. Virgin Islands (1)

Ford Motor 

Company 

7 172,468 358,360 54 2

Bermuda (1)

Cayman Islands (1)

Freddie Mac 53 43,104 0 0 0 

General Dynamics 

Corporation 

84 27,294 13,905,516 51 5

Cyprus (1)

Singapore (1)

Switzerland (3)

General Electric

Company 

6 176,656 2,780,528 40 7

Bermuda (3)

Luxembourg (1)

Singapore (3)

Page 28 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix II: The 100 Largest Publicly Traded 

U.S. Corporations 

Corporation 

Rank by

revenue

2007 Revenue

(dollars in 

millions) 

Federal contract 

obligations for

fiscal year 2007 

(dollars in thousands)

a

Number of foreign

subsidiaries 

Number and location(s) of

subsidiaries in jurisdictions 

listed as tax havens or financial 

privacy jurisdictions

General Motors

Corporation 

4 182,347 517,205 113 11

Barbados (1)

Bermuda (2)

Cayman Islands (4)

Ireland (1)

Singapore (1)

Switzerland (2)

GMAC 77 31,490 0 56 2

Bermuda (1)

Switzerland (1)

Goldman Sachs 

Group 

20 87,968 356 55 29

Bermuda (3)

British Virgin Islands (1)

Cayman Islands (15)

Hong Kong (3)

Ireland (1)

Jersey (1)

Mauritius (5)

Hartford Financial 

Services 

90 25,916 353 32 10

Bermuda (7)

Ireland (3)

Hess Corporation 76 31,924 240,500 11 5

Cayman Islands (4)

U.S. Virgin Islands (1)

Hewlett–Packard 

Company 

14 104,286 374,297 81 14

Cayman Islands (1)

Costa Rica (1)

Hong Kong (1)

Ireland (3)

Latvia (1)

Netherlands Antilles (1)

Singapore (4)

Switzerland (2)

Home Depot 22 84,740 2,304 0 0 

Page 29 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix II: The 100 Largest Publicly Traded 

U.S. Corporations 

Corporation 

Rank by

revenue

2007 Revenue

(dollars in 

millions) 

Federal contract 

obligations for

fiscal year 2007 

(dollars in thousands)

a

Number of foreign

subsidiaries 

Number and location(s) of

subsidiaries in jurisdictions 

listed as tax havens or financial 

privacy jurisdictions

Honeywell

International, Inc. 

72 34,589 2,491,103 35 7

Bermuda (1)

Luxembourg (3)

Singapore (1)

Switzerland (2)

Humana 93 25,290 37,863 5 0

Ingram Micro 68 35,047 0 104 33

Barbados (1)

Bermuda (2)

British Virgin Islands (1)

Cayman Islands (8)

Hong Kong (6)

Luxembourg (1)

Mauritius (2)

Panama (1)

Singapore (10)

Switzerland (1)

Intel 59 38,334 0 15 6

Cayman Islands (5)

Costa Rica (1)

International 

Business Machines 

Corporation 

15 98,786 1,427,788 70 10

Bahamas (1)

Barbados (1)

Bermuda (1)

Costa Rica (1)

Hong Kong (1)

Ireland (1)

Latvia (1)

Luxembourg (1)

Singapore (1)

Switzerland (1)

Page 30 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix II: The 100 Largest Publicly Traded 

U.S. Corporations 

Corporation 

Rank by

revenue

2007 Revenue

(dollars in 

millions) 

Federal contract 

obligations for

fiscal year 2007 

(dollars in thousands)

a

Number of foreign

subsidiaries 

Number and location(s) of

subsidiaries in jurisdictions 

listed as tax havens or financial 

privacy jurisdictions

J.P. Morgan Chase 

& Co. 

12 116,353 55,337 163 50

Bahamas (1)

Bermuda (2)

British Virgin Islands (4)

Cayman Islands (7)

Channel Islands (4)

Hong Kong (8)

Ireland (2)

Luxembourg (8)

Mauritius (8)

Singapore (5)

Switzerland (1)

Johnson & Johnson 34 61,095 170,246 175 38

Hong Kong (2)

Ireland (16)

Luxembourg (1)

Panama (1)

Singapore (1)

Switzerland (17)

Johnson Controls 71 34,678 120,645 0 0 

Kraft Foods, Inc. 62 37,241 348,708 255 36

Bahamas (1)

Bahrain (1)

British Virgin Islands (2)

Cayman Islands (1)

Costa Rica (3)

Hong Kong (4)

Ireland (4)

Latvia (1)

Liberia (2)

Luxembourg (2)

Panama (1)

Singapore (8)

Switzerland (6)

Kroger 26 70,235 86 1 1

Hong Kong (1)

Page 31 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix II: The 100 Largest Publicly Traded 

U.S. Corporations 

Corporation 

Rank by

revenue

2007 Revenue

(dollars in 

millions) 

Federal contract 

obligations for

fiscal year 2007 

(dollars in thousands)

a

Number of foreign

subsidiaries 

Number and location(s) of

subsidiaries in jurisdictions 

listed as tax havens or financial 

privacy jurisdictions

Lehman Brothers 

Holdings 

36 59,003 25 141 57

Bermuda (2)

Cayman Islands (31)

Hong Kong (9)

Ireland (1)

Luxembourg (6)

Mauritius (3)

Singapore (5)

Lockheed Martin 

Corporation 

56 41,862 32,784,881 0 0

Lowe’s 47 48,283 717 0 0

Macy’s 87 26,340 0 0 0

Marathon Oil 35 60,044 50 115 76

Bahamas (1)

Barbados (1)

Bermuda (3)

Cayman Islands (65)

Cyprus (1)

Ireland (2)

Liberia (1)

Luxembourg (1)

Switzerland (1)

McDonald’s 100 23,231 0 34 5

Hong Kong (2)

Switzerland (3)

McKesson 

Corporation 

18 93,574 4,692,110 1 1

Ireland (1)

Medco Health 

Solutions 

50 44,506 261 0 0

Page 32 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix II: The 100 Largest Publicly Traded 

U.S. Corporations 

Corporation 

Rank by

revenue

2007 Revenue

(dollars in 

millions) 

Federal contract 

obligations for

fiscal year 2007 

(dollars in thousands)

a

Number of foreign

subsidiaries 

Number and location(s) of

subsidiaries in jurisdictions 

listed as tax havens or financial 

privacy jurisdictions

Merck & Co., Inc. 95 24,198 1,418,213 199 44

Barbados (2)

Bermuda (14)

Cyprus (1)

Hong Kong (3)

Ireland (7)

Latvia (1)

Lebanon (1)

Luxembourg (2)

Panama (2)

Singapore (6)

Switzerland (5)

Merrill Lynch 30 64,217 500 82 21

Bermuda (2)

Cayman Islands (3)

Hong Kong (4)

Ireland (2)

Luxembourg (1)

Mauritius (3)

Netherlands Antilles (1)

Singapore (2)

Switzerland (3)

MetLife 42 53,150 1,873 84 19

Barbados (5)

Bermuda (3)

Cayman Islands (5)

Hong Kong (2)

Ireland (2)

Singapore (1)

Virgin Islands (1)

b

Microsoft 43 51,122 48,717 14 8

Bermuda (2)

Ireland (5)

Singapore (1)

Page 33 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix II: The 100 Largest Publicly Traded 

U.S. Corporations 

Corporation 

Rank by

revenue

2007 Revenue

(dollars in 

millions) 

Federal contract 

obligations for

fiscal year 2007 

(dollars in thousands)

a

Number of foreign

subsidiaries 

Number and location(s) of

subsidiaries in jurisdictions 

listed as tax havens or financial 

privacy jurisdictions

Morgan Stanley 21 87,879 14,062 568 273

Bermuda (3)

British Virgin Islands (1)

Cayman Islands (158)

Cyprus (2)

Gibraltar (2)

Hong Kong (15)

Ireland (6)

Jersey (19)

Liberia (5)

Luxembourg (29)

Malta (1)

Marshall Islands (14)

Mauritius (4)

Panama (1)

Singapore (9)

Switzerland (4)

Motorola, Inc. 64 36,622 321,347 24 4

Hong Kong (1)

Singapore (3)

News Corporation 82 28,655 2,646 782 152

Belize (1)

Bermuda (1)

British Virgin Islands (62)

Cayman Islands (33)

Cyprus (1)

Hong Kong (21)

Ireland (1)

Latvia (4)

Luxembourg (4)

Marshall Islands (1)

Mauritius (15)

Panama (1)

Singapore (5)

Switzerland (2)

Northrop Grumman 

Corporation 

75 32,032 15,991,673 0 0

Page 34 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix II: The 100 Largest Publicly Traded 

U.S. Corporations 

Corporation 

Rank by

revenue

2007 Revenue

(dollars in 

millions) 

Federal contract 

obligations for

fiscal year 2007 

(dollars in thousands)

a

Number of foreign

subsidiaries 

Number and location(s) of

subsidiaries in jurisdictions 

listed as tax havens or financial 

privacy jurisdictions

PepsiCo, Inc. 58 39,474 218,353 356 70

Bahamas (1)

Barbados (1)

Bermuda (13)

Cayman Islands (2)

Costa Rica (2)

Cyprus (5)

Gibraltar (1)

Hong Kong (10)

Ireland (9)

Jordan (1)

Latvia (1)

Liechtenstein (1)

Luxembourg (7)

Mauritius (2)

Netherlands Antilles (6)

Panama (1)

Singapore (1)

Switzerland (6)

Pfizer 46 48,418 40,609 356 80

Bahamas (1)

Bermuda (3)

Cayman Islands (1)

Costa Rica (2)

Guernsey (1)

Hong Kong (4)

Ireland (28)

Jersey (10)

Luxembourg (16)

Panama (3)

Singapore (6)

Switzerland (4)

Virgin Islands (1)

b

Page 35 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix II: The 100 Largest Publicly Traded 

U.S. Corporations 

Corporation 

Rank by

revenue

2007 Revenue

(dollars in 

millions) 

Federal contract 

obligations for

fiscal year 2007 

(dollars in thousands)

a

Number of foreign

subsidiaries 

Number and location(s) of

subsidiaries in jurisdictions 

listed as tax havens or financial 

privacy jurisdictions

The Procter & 

Gamble Company 

23 76,476 312,828 581 83

Barbados (1)

Belize (1)

Bermuda (5)

British Virgin Islands (2)

Cayman Islands (2)

Costa Rica (3)

Hong Kong (10)

Ireland (11)

Latvia (1)

Lebanon (2)

Liechtenstein (1)

Luxembourg (6)

Panama (3)

Singapore (11)

Switzerland (24)

Prudential Financial 73 34,401 35,768 116 27

Barbados (1)

Bermuda (9)

Cayman Islands (5)

Hong Kong (7)

Ireland (1)

Luxembourg (1)

Singapore (3)

Safeway 54 42,286 141 18 4

Bermuda (1)

British Virgin Islands (1)

Hong Kong (1)

Macao (1)

Sears Holdings 44 50,703 315 2 1

Bermuda (1)

Sprint Nextel

Corporation 

57 40,146 142,754 59 7

Bermuda (1)

Hong Kong (2)

Ireland (1)

Singapore (1)

Switzerland (2)

Page 36 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix II: The 100 Largest Publicly Traded 

U.S. Corporations 

Corporation 

Rank by

revenue

2007 Revenue

(dollars in 

millions) 

Federal contract 

obligations for

fiscal year 2007 

(dollars in thousands)

a

Number of foreign

subsidiaries 

Number and location(s) of

subsidiaries in jurisdictions 

listed as tax havens or financial 

privacy jurisdictions

Sunoco 55 42,101 68 11 5

Bermuda (4)

Panama (1)

SuperValu 61 37,406 1,520 6 5

Bermuda (4)

Cayman Islands (1)

SYSCO Corporation 69 35,042 173,586 31 1

Hong Kong (1)

Target 31 63,367 0 19 8

Bermuda (1)

Hong Kong (6)

Singapore (1)

Tech Data 99 23,423 0 67 7

Cayman Islands (1)

Costa Rica (1)

Ireland (1)

Luxembourg (1)

Netherlands Antilles (1)

Switzerland (2)

Time Warner 48 46,615 7,575 48 4

Hong Kong (2)

Ireland (1)

Luxembourg (1)

Travelers 

Companies 

89 26,017 535 27 6

Bermuda (4)

Cayman Islands (1)

Singapore (1)

Tyson Foods, Inc. 85 26,900 326,553 41 6

Bermuda (1)

Cayman Islands (1)

Gibraltar (1)

Hong Kong (1)

Luxembourg (2)

United Parcel 

Service, Inc. 

45 49,692 140,771 0 0

Page 37 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix II: The 100 Largest Publicly Traded 

U.S. Corporations 

Corporation 

Rank by

revenue

2007 Revenue

(dollars in 

millions) 

Federal contract 

obligations for

fiscal year 2007 

(dollars in thousands)

a

Number of foreign

subsidiaries 

Number and location(s) of

subsidiaries in jurisdictions 

listed as tax havens or financial 

privacy jurisdictions

United 

Technologies 

Corporation 

38 54,759 5,714,807 93 12

Cayman Islands (1)

Hong Kong (2)

Ireland (1)

Luxembourg (4)

Singapore (4)

UnitedHealth Group 25 75,431 1,524 54 11

Bermuda (1)

Cayman Islands (2)

Costa Rica (2)

Hong Kong (2)

Ireland (2)

Mauritius (1)

Singapore (1)

Valero Energy 

Corporation 

16 96,758 1,027,334 23 11

Aruba (5)

Bermuda (1)

British Virgin Islands (3)

Cayman Islands (2)

Verizon 

Communications, 

Inc. 

17 93,775 428,654 0 0

Wachovia 

Corporation 

37 55,528 3,683 105 59

Aruba (1)

Barbados (1)

Bermuda (18)

British Virgin Islands (3)

Cayman Islands (16)

Guernsey (1)

Hong Kong (9)

Ireland (2)

Mauritius (3)

Singapore (2)

Turks and Caicos Islands (1)

U.S. Virgin Islands (2)

Walgreen 39 53,762 17 4 2

Mauritius (2)

Wal–Mart Stores 1 378,799 173 1 0 

Page 38 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix II: The 100 Largest Publicly Traded 

U.S. Corporations 

Corporation 

Rank by

revenue

2007 Revenue

(dollars in 

millions) 

Federal contract 

obligations for

fiscal year 2007 

(dollars in thousands)

a

Number of foreign

subsidiaries 

Number and location(s) of

subsidiaries in jurisdictions 

listed as tax havens or financial 

privacy jurisdictions

Walt Disney 66 35,882 1,224 15 3

Hong Kong (2)

Switzerland (1)

Washington Mutual 92 25,531 556 5 3

Hong Kong (1)

Mauritius (1)

Virgin Islands (1)

b

WellPoint 32 61,134 72,575 3 1

Bermuda (1)

Wells Fargo 40 53,593 37,777 34 18

Barbados (1)

Cayman Islands (9)

Hong Kong (4)

Mauritius (4)

Sources: Fortune 500 list for 2008 (which is based on 2007 revenues), USASpending.gov, Exhibit 21s filed with the Securities and 

Exchange Commission, and jurisdictions listed as tax havens or financial privacy jurisdictions. 

a

Federal contract obligations are estimates. The actual contract obligations may be greater. 

b

Abbot Laboratories, Delphi, Dow Chemical, MetLife, Pfizer, and Washington Mutual did not 

differentiate between the U.S. Virgin Islands and the British Virgin Islands. Therefore, for the purpose 

of this list, they are listed as Virgin Islands. 

Page 39 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix III: The 100 Largest Publicly Traded

U.S. Federal Contractors 

Contractor

Rank by federal 

contract 

obligations

Federal contract 

obligations for

fiscal year 2007 

(dollars in 

thousands)

a

Number of foreign

subsidiaries

Number and locations of subsidiaries 

in jurisdictions listed as tax havens 

or financial privacy jurisdictions

AAR Corporation 79 $196,565 0 0

AECOM Technology 48 417,324 0 0 

AeroVironment, Inc. 83 185,261 0 0 

Affiliated Computer 

Services, Inc. 

72 218,586 55 7

Barbados (1)

Hong Kong (2)

Ireland (1)

Luxembourg (1)

Switzerland (2)

Alliant Techsystems, Inc. 24 1,422,471 0 0 

AmerisourceBergen

Corporation 

21 1,469,378 0 0

Archer-Daniels-Midland 

Company 

78 197,488 6 3

Cayman Islands (2)

Ireland (1)

AT&T, Inc. 40 519,233 0 0 

BearingPoint, Inc. 38 520,725 106 28

Aruba (2)

Barbados (1)

Bermuda (11)

British Virgin Islands (2)

Cayman Islands (2)

Costa Rica (1)

Jordan (1)

Ireland (1)

Panama (1)

Switzerland (1)

Singapore (4)

U.S. Virgin Islands (1)

Berkshire Hathaway, Inc. 70 235,394 27 1

Ireland (1)

Appendix III: The 100 Largest Publicly Traded 

U.S. Federal Contractors 

Page 40 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix III: The 100 Largest Publicly Traded

U.S. Federal Contractors 

Contractor

Rank by federal 

contract 

obligations

Federal contract 

obligations for

fiscal year 2007 

(dollars in 

thousands)

a

Number of foreign

subsidiaries

Number and locations of subsidiaries 

in jurisdictions listed as tax havens 

or financial privacy jurisdictions

The Boeing Company 2 23,312,965 135 38

Bermuda (6)

Cayman Islands (1)

Gibraltar (2)

Hong Kong (4)

Ireland (4)

Netherlands Antilles (2)

Singapore (3)

U.S. Virgin Islands (16)

CACI International, Inc. 22 1,443,230 1 0 

Cardinal Health, Inc. 30 1,039,243 135 23

Barbados (1)

Bermuda (2)

British Virgin Islands (1)

Cayman Islands (1)

Hong Kong (1)

Ireland (5)

Luxembourg (3)

Malta (1)

Mauritius (1)

Singapore (3)

Switzerland (4)

Caterpillar, Inc. 89 171,485 331 49

Barbados (1)

Bermuda (13)

Costa Rica (1)

Guernsey (1)

Hong Kong (3)

Ireland (2)

Luxembourg (3)

Mauritius (1)

Panama (3)

Singapore (8)

Switzerland (13)

Ceradyne, Inc. 43 463,590 7 2

Cayman Islands (1)

Hong Kong (1)

Page 41 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix III: The 100 Largest Publicly Traded

U.S. Federal Contractors 

Contractor

Rank by federal 

contract 

obligations

Federal contract 

obligations for

fiscal year 2007 

(dollars in 

thousands)

a

Number of foreign

subsidiaries

Number and locations of subsidiaries 

in jurisdictions listed as tax havens 

or financial privacy jurisdictions

Computer Sciences 

Corporation 

10 3,189,701 119 21

Bermuda (1)

British Virgin Islands (4)

Costa Rica (1)

Hong Kong (5)

Ireland (2)

Luxembourg (2)

Macao (1)

Singapore (4)

Switzerland (1)

Comtech 

Telecommunications 

Corporation 

62 286,461 1 0

ConAgra Foods, Inc. 97 148,713 2 0 

ConocoPhillips 65 267,206 125 44

Bahamas (2)

Bermuda (17)

British Virgin Islands (2)

Cayman Islands (9)

Ireland (3)

Liberia (5)

Luxembourg (2)

Marshall Islands (1)

Singapore (1)

Switzerland (2)

Constellation Energy 

Group, Inc. 

91 166,060 0 0

Cornell Companies, Inc. 63 282,588 0 0 

Corrections Corporation of 

America 

46 447,008 2 0

Cubic Corporation 52 359,911 8 1

U.S. Virgin Islands (1)

Page 42 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix III: The 100 Largest Publicly Traded

U.S. Federal Contractors 

Contractor

Rank by federal 

contract 

obligations

Federal contract 

obligations for

fiscal year 2007 

(dollars in 

thousands)

a

Number of foreign

subsidiaries

Number and locations of subsidiaries 

in jurisdictions listed as tax havens 

or financial privacy jurisdictions

Danaher Corporation 98 147,214 548 72

Barbados (1)

Cayman Islands (9)

Hong Kong (14)

Ireland (5)

Luxembourg (4)

Malta (1)

Mauritius (2)

Singapore (13)

St. Kitts and Nevis (1)

Switzerland (22)

Dell, Inc. 28 1,132,476 158 29

Bahrain (1)

Barbados (1)

Cayman Islands (4)

Costa Rica (2)

Hong Kong (1)

Ireland (10)

Lebanon (1)

Luxembourg (1)

Panama (1)

Singapore (5)

Switzerland (2)

DRS Technologies, Inc. 18 1,795,032 9 0 

Eaton Corporation 87 173,671 164 37

Barbados (2)

Bermuda (4)

British Virgin Islands (3)

Cayman Islands (5)

Costa Rica (1)

Hong Kong (4)

Ireland (1)

Luxembourg (5)

Mauritius (4)

Netherlands Antilles (1)

Singapore (5)

Switzerland (2)

Page 43 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix III: The 100 Largest Publicly Traded

U.S. Federal Contractors 

Contractor

Rank by federal 

contract 

obligations

Federal contract 

obligations for

fiscal year 2007 

(dollars in 

thousands)

a

Number of foreign

subsidiaries

Number and locations of subsidiaries 

in jurisdictions listed as tax havens 

or financial privacy jurisdictions

Electronic Data Systems 

Corporation 

17 2,312,022 137 19

Bahrain (1)

Bermuda (1)

British Virgin Islands (1)

Cayman Islands (2)

Costa Rica (1)

Guernsey (1)

Hong Kong (1)

Ireland (1)

Luxembourg (2)

Mauritius (2)

Panama (1)

Singapore (3)

Switzerland (2)

Emergent Biosolutions, Inc. 45 448,352 5 1

Singapore (1)

Exxon Mobil Corporation 32 949,152 122 32

Bahamas (18)

Bermuda (1)

Cayman Islands (3)

Hong Kong (3)

Ireland (1)

Luxembourg (2)

Singapore (3)

Switzerland (1)

Flir Systems, Inc.b67 249,658 Unknown Unknown

Fluor Corporation 20 1,506,242 197 34

Barbados (2)

Bermuda (7)

British Virgin Islands (2)

Cyprus (2)

Guernsey (9)

Ireland (5)

Liechtenstein (2)

Mauritius (3)

Panama (1)

St. Lucia (1)

Force Protection, Inc. 27 1,139,550 0 0 

Page 44 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix III: The 100 Largest Publicly Traded

U.S. Federal Contractors 

Contractor

Rank by federal 

contract 

obligations

Federal contract 

obligations for

fiscal year 2007 

(dollars in 

thousands)

a

Number of foreign

subsidiaries

Number and locations of subsidiaries 

in jurisdictions listed as tax havens 

or financial privacy jurisdictions

Ford Motor Company 53 358,360 54 2

Bermuda (1)

Cayman Islands (1)

General Dynamics 

Corporation 

4 13,905,516 51 5

Cyprus (1)

Singapore (1)

Switzerland (3)

General Electric Company 11 2,780,528 40 7

Bermuda (3)

Luxembourg (1)

Singapore (3)

General Mills, Inc. 81 193,621 171 33

Aruba (1)

Bermuda (5)

British Virgin Islands (2)

Gibraltar (1)

Hong Kong (5)

Lebanon (2)

Luxembourg (1)

Mauritius (2)

Netherlands Antilles (1)

Panama (1)

Singapore (4)

Switzerland (8)

General Motors Corporation 41 517,205 113 11

Barbados (1)

Bermuda (2)

Cayman Islands (4)

Ireland (1)

Singapore (1)

Switzerland (2)

Page 45 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix III: The 100 Largest Publicly Traded

U.S. Federal Contractors 

Contractor

Rank by federal 

contract 

obligations

Federal contract 

obligations for

fiscal year 2007 

(dollars in 

thousands)

a

Number of foreign

subsidiaries

Number and locations of subsidiaries 

in jurisdictions listed as tax havens 

or financial privacy jurisdictions

Goodrich Corporation 56 326,475 72 17

Barbados (2)

Gibraltar (3)

Hong Kong (1)

Luxembourg (5)

Mauritius (1)

Singapore (4)

Virgin Islands (1)

c

The Goodyear Tire & 

Rubber Company 

85 182,072 165 13

Bermuda (1)

Ireland (2)

Luxembourg (6)

Mauritius (1)

Singapore (2)

Switzerland (1)

Great Lakes Dredge & 

Dock Corporation 

68 246,606 0 0

GTSI Corporation 49 399,060 0 0 

Harris Corporation 19 1,741,545 71 13

Bermuda (1)

Cayman Islands (1)

Hong Kong (5)

Mauritius (1)

Singapore (4)

U.S. Virgin Islands (1)

Hess Corporation 69 240,500 11 5

Cayman Islands (4)

U.S. Virgin Islands (1)

Hewlett-Packard Company 50 374,297 81 14

Cayman Islands (1)

Costa Rica (1)

Hong Kong (1)

Ireland (3)

Latvia (1)

Netherlands Antilles (1)

Singapore (4)

Switzerland (2)

Page 46 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix III: The 100 Largest Publicly Traded

U.S. Federal Contractors 

Contractor

Rank by federal 

contract 

obligations

Federal contract 

obligations for

fiscal year 2007 

(dollars in 

thousands)

a

Number of foreign

subsidiaries

Number and locations of subsidiaries 

in jurisdictions listed as tax havens 

or financial privacy jurisdictions

Honeywell International, 

Inc. 

13 2,491,103 35 7

Bermuda (1)

Luxembourg (3)

Singapore (1)

Switzerland (2)

ICF International, Inc. 92 165,488 7 0 

International Business 

Machines Corporation 

23 1,427,788 70 10

Bahamas (1)

Barbados (1)

Bermuda (1)

Costa Rica (1)

Hong Kong (1)

Ireland (1)

Latvia (1)

Luxembourg (1)

Singapore (1)

Switzerland (1)

International Shipholding 

Corporation 

94 162,236 13 11

Bermuda (1)

British Virgin Islands (4)

Cayman Islands (1)

Marshall Islands (2)

Panama (1)

Singapore (2)

Interpublic Group of 

Companies, Inc. 

44 462,229 120 5

Ireland (1)

Luxembourg (1)

Mauritius (1)

Singapore (1)

Switzerland (1)

Page 47 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix III: The 100 Largest Publicly Traded

U.S. Federal Contractors 

Contractor

Rank by federal 

contract 

obligations

Federal contract 

obligations for

fiscal year 2007 

(dollars in 

thousands)

a

Number of foreign

subsidiaries

Number and locations of subsidiaries 

in jurisdictions listed as tax havens 

or financial privacy jurisdictions

ITT Corporation 14 2,377,121 170 18

Barbados (1)

Bermuda (1)

Cayman Islands (1)

Hong Kong (3)

Ireland (3)

Luxembourg (5)

Singapore (2)

Switzerland (1)

Virgin Islands (1)

c

Jacobs Engineering Group, 

Inc. 

29 1,051,891 58 11

Hong Kong (1)

Ireland (2)

Luxembourg (1)

Singapore (5)

U.S. Virgin Islands (1)

Virgin Islands (1)

c

Johnson & Johnson 90 170,246 175 38

Hong Kong (2)

Ireland (16)

Luxembourg (1)

Panama (1)

Singapore (1)

Switzerland (17)

KBR, Inc. 8 4,794,248 5 0 

Page 48 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix III: The 100 Largest Publicly Traded

U.S. Federal Contractors 

Contractor

Rank by federal 

contract 

obligations

Federal contract 

obligations for

fiscal year 2007 

(dollars in 

thousands)

a

Number of foreign

subsidiaries

Number and locations of subsidiaries 

in jurisdictions listed as tax havens 

or financial privacy jurisdictions

Kraft Foods, Inc. 54 348,708 255 36

Bahamas (1)

Bahrain (1)

British Virgin Islands (2)

Cayman Islands (1)

Costa Rica (3)

Hong Kong (4)

Ireland (4)

Latvia (1)

Liberia (2)

Luxembourg (2)

Panama (1)

Singapore (8)

Switzerland (6)

L-3 Communications 

Holdings, Inc. 

6 6,636,283 90 15

Barbados (1)

Bermuda (1)

Cayman Islands (1)

Costa Rica (1)

Hong Kong (2)

Ireland (1)

Singapore (5)

U.S. Virgin Islands (3)

Lockheed Martin 

Corporation 

1 32,784,881 0 0

Mantech International 

Corporation 

37 546,746 7 1

Panama (1)

McDermott International, 

Inc. 

77 199,070 5 5

Panama (5)

McKesson Corporation 9 4,692,110 1 1

Ireland (1)

Page 49 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix III: The 100 Largest Publicly Traded

U.S. Federal Contractors 

Contractor

Rank by federal 

contract 

obligations

Federal contract 

obligations for

fiscal year 2007 

(dollars in 

thousands)

a

Number of foreign

subsidiaries

Number and locations of subsidiaries 

in jurisdictions listed as tax havens 

or financial privacy jurisdictions

Merck & Co., Inc. 25 1,418,213 199 44

Barbados (2)

Bermuda (14)

Cyprus (1)

Hong Kong (3)

Ireland (7)

Latvia (1)

Lebanon (1)

Luxembourg (2)

Panama (2)

Singapore (6)

Switzerland (5)

Motorola, Inc. 58 321,347 24 4

Hong Kong (1)

Singapore (3)

Navistar International 

Corporation 

61 304,016 4 1

Cayman Islands (1)

NCI, Inc. 75 208,545 0 0 

Northrop Grumman 

Corporation 

3 15,991,673 0 0

Olin Corporation 64 271,445 7 1

Bermuda (1)

Oracle Corporation 93 164,665 297 77

Barbados (3)

Bermuda (1)

British Virgin Islands (1)

Cayman Islands (5)

Costa Rica (1)

Cyprus (1)

Hong Kong (12)

Ireland (22)

Isle of Man (1)

Jersey (1)

Luxembourg (6)

Mauritius (1)

Netherlands Antilles (1)

Singapore (16)

Switzerland (5)

Page 50 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix III: The 100 Largest Publicly Traded

U.S. Federal Contractors 

Contractor

Rank by federal 

contract 

obligations

Federal contract 

obligations for

fiscal year 2007 

(dollars in 

thousands)

a

Number of foreign

subsidiaries

Number and locations of subsidiaries 

in jurisdictions listed as tax havens 

or financial privacy jurisdictions

Orbital Sciences

Corporation 

96 158,483 0 0

Oshkosh Truck Corporation 16 2,339,964 52 6

Barbados (2)

Cayman Islands (2)

Hong Kong (1)

Mauritius (1)

Owens & Minor, Inc. 66 257,284 1 1

British Virgin Islands (1)

Pepco Holdings, Inc. 71 234,070 0 0

PepsiCo, Inc. 73 218,353 356 70

Bahamas (1)

Barbados (1)

Bermuda (13)

Cayman Islands (2)

Costa Rica (2)

Cyprus (5)

Gibraltar (1)

Hong Kong (10)

Ireland (9)

Jordan (1)

Latvia (1)

Liechtenstein (1)

Luxembourg (7)

Mauritius (2)

Netherlands Antilles (6)

Panama (1)

Singapore (1)

Switzerland (6)

Perot Systems Corporation 60 312,643 38 13

Bermuda (2)

Hong Kong (1)

Ireland (2)

Luxembourg (1)

Mauritius (1)

Singapore (3)

Switzerland (3)

Point Blank Solutions, Inc. 76 206,202 0 0 

Page 51 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix III: The 100 Largest Publicly Traded

U.S. Federal Contractors 

Contractor

Rank by federal 

contract 

obligations

Federal contract 

obligations for

fiscal year 2007 

(dollars in 

thousands)

a

Number of foreign

subsidiaries

Number and locations of subsidiaries 

in jurisdictions listed as tax havens 

or financial privacy jurisdictions

The Procter & Gamble 

Company 

59 312,828 581 83

Barbados (1)

Belize (1)

Bermuda (5)

British Virgin Islands (2)

Cayman Islands (2)

Costa Rica (3)

Hong Kong (10)

Ireland (11)

Latvia (1)

Lebanon (2)

Liechtenstein (1)

Luxembourg (6)

Panama (3)

Singapore (11)

Switzerland (24)

Raytheon Company 5 11,793,187 0 0 

Res-Care, Inc. 95 160,359 0 0 

Rockwell Collins, Inc. 26 1,219,054 20 4

Bermuda (2)

Luxembourg (1)

Singapore (1)

The Shaw Group, Inc.b42 491,729 Unknown Unknown

SI International, Inc.b82 191,954 Unknown Unknown

Sprint Nextel Corporation 99 142,754 59 7

Bermuda (1)

Hong Kong (2)

Ireland (1)

Singapore (1)

Switzerland (2)

SRA International, Inc. 35 661,871 10 0

Stanley, Inc. 57 321,922 0 0 

SYSCO Corporation 88 173,586 31 1

Hong Kong (1)

Teledyne, Inc. 51 372,709 15 2

Bermuda (1)

Singapore (1)

Page 52 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix III: The 100 Largest Publicly Traded

U.S. Federal Contractors 

Contractor

Rank by federal 

contract 

obligations

Federal contract 

obligations for

fiscal year 2007 

(dollars in 

thousands)

a

Number of foreign

subsidiaries

Number and locations of subsidiaries 

in jurisdictions listed as tax havens 

or financial privacy jurisdictions

Telos Corporation 84 183,777 0 0 

Tesoro Corporation 74 210,342 0 0 

Tetra Tech, Inc. 36 604,922 6 1

British Virgin Islands (1)

Textron, Inc. 15 2,364,772 98 5

Barbados (1)

Singapore (2)

Switzerland (2)

Tyson Foods, Inc. 55 326,553 41 6

Bermuda (1)

Cayman Islands (1)

Gibraltar (1)

Hong Kong (1)

Luxembourg (2)

Unisys Corporation 33 807,003 3 0 

United Parcel Service, Inc. 100 140,771 0 0 

United Technologies 

Corporation 

7 5,714,807 93 12

Cayman Islands (1)

Hong Kong (2)

Ireland (1)

Luxembourg (4)

Singapore (4)

URS Corporation 12 2,643,385 276 24

Bahrain (2)

Bermuda (4)

Hong Kong (2)

Ireland (2)

Jordan (4)

Singapore (4)

U.S. Virgin Islands (2)

Virgin Islands (4)

c

Valero Energy Corporation 31 1,027,334 23 11

Aruba (5)

Bermuda (1)

British Virgin Islands (3)

Cayman Islands (2)

Page 53 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix III: The 100 Largest Publicly Traded

U.S. Federal Contractors 

Contractor

Rank by federal 

contract 

obligations

Federal contract 

obligations for

fiscal year 2007 

(dollars in 

thousands)

a

Number of foreign

subsidiaries

Number and locations of subsidiaries 

in jurisdictions listed as tax havens 

or financial privacy jurisdictions

Verizon Communications, 

Inc. 

47 428,654 0 0

Viasat, Inc. 80 195,071 5 1

Switzerland (1)

VSE Corporation 34 706,444 0 0 

Wyeth-Ayerst International, 

Inc. 

39 519,750 32 4

Ireland (2)

Singapore (1)

Switzerland (1)

Xerox Corporation 86 179,963 164 33

Barbados (4)

Bermuda (8)

Hong Kong (1)

Ireland (12)

Jersey (1)

Luxembourg (2)

Mauritius (1)

Singapore (1)

Switzerland (2)

Turks and Caicos Islands (1)

Sources: USASpending.gov, Exhibit 21s filed with the SEC, and jurisdictions listed as tax havens or financial privacy jurisdictions. 

a

Federal contract obligations are estimates. The actual contract obligations may be greater. 

b

Flir Systems, Inc. did not list locations for some subsidiaries and The Shaw Group, Inc. and SI 

International, Inc. did not list locations for any subsidiaries. 

c

Goodrich Corporation, ITT Corporation, Jacobs Engineering Group, Inc., and URS Corporation did 

not always differentiate between the U.S. Virgin Islands and the British Virgin Islands. Therefore, for 

the purpose of this list, they are listed as Virgin Islands. 

Page 54 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix IV: Comments from the Department 

of the Treasury 

Page 55 GAO-09-157 U.S. Corporations with Foreign Subsidiaries

Appendix IV: Comments from the 

Department of the Treasury 
Appendix IV: Comments from the Department 

of the Treasury

Page 56 GAO-09-157 U.S. Corporations with Foreign Subsidiaries
Appendix V: Comments from the Internal

Revenue Service 

Page 57 GAO-09-157 U.S. Corporations with Foreign Subsidiaries

Appendix V: Comments from the Internal 

Revenue Service 
Appendix VI: 

A

GAO Contact and Staff 

cknowledgments 

Page 58 GAO-09-157 U.S. Corporations with Foreign Subsidiaries

James R. White, (202) 512-9110 or whitej@gao.gov

In addition to the contact named above, Jonda Van Pelt, Assistant 

Director; Joanna Berry; Michele Fejfar; Julia Kennon; Audrey Ruge; 

Shellee Soliday; A. J. Stephens; and Megan Sullivan made key 

contributions to this report. 

Appendix VI: GAO Contact and Staff 

Acknowledgments 

GAO Contact 

Acknowledgments 

(450658) 
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