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"In theoretical physics, dark matter is the stuff in the universe that we can identify only by its gravitational pull. [In theoretical economics], dark matter is foreign wealth, the existence of which we can infer from the income it provides."' On April 9, 1998, the Organization for Economic Cooperation and Development (OECD) issued a report spotlighting countries that facilitate the accumulation of dark matter.2 Generally referred to as "tax havens," these countries are problematic not only to economists, who are forced to infer the amount of wealth held within their jurisdictions, but also to the international community;3 tax havens facilitate tax avoidance, tax evasion, and criminal activity, such as money laundering and embezzlement. 4 Tax avoidance and tax evasion jeopardize government revenues worldwide. 5 U.S. revenue losses have been estimated at $100 billion a year, and 6 many European countries suffer losses exceeding billions of euros. "Individually tax havens may appear small and insignificant, but in combination they play an important role in the world economy.",7 This is especially true in the financial services industry,8 where the use of tax havens is particularly relevant.9 Because all industries utilize banks and insurance companies, the scope of the financial services industry and the resulting influence of tax havens on the global economy are particularly broad. 10 For example, offshore entities were integral to the Enron and Bayou Management

Automatic Information Exchange as a Multilateral Solution to Tax Havens