Chris Horton (J.D. 2011, Miami) has published Note, The UBS/IRS Settlement Agreement and Cayman Island Hedge Funds, 41 U. Miami Inter-Am. L. Rev. 357 (2010). Here is part of the Introduction:

This article will argue that the IRS v. UBS settlement was not a “major step forward”” in the fight against tax evasion; the only way for the U.S. government to take a major step forward is by passing legislation aimed at curbing tax evasion practices. The first section will define hedge fund and address laws that have made the Cayman Islands the largest hedge fund domicile in the world. This section will also address the chief tax evasion practices the IRS suspects is taking place in the Cayman Islands. The second section will analyze the relationship between the U.S. and the Cayman Islands in regard to tax evasion. This section will examine the methods that the United States has used to curb tax evasion: in particular, establishing the Organisation for Economic Co-operation and Development and the Tax Information Exchange Agreements. Section three will discuss the IRS v. UBS case and its settlement agreement. Next, the article will examine whether the IRS would have similar success with Cayman Islands hedge funds through a “John Doe” summons. It will also analyze the issues the U.S. government faces with the UBS settlement agreement and future legal action against the Cayman Islands. The article will conclude with a forecast of what hedge fund corporations and their investors in the Cayman Islands will do to prepare for an anticipated focus by the IRS on the Cayman Islands.