Sovereign Threshold

The Property Thesis · 2 of 8

Offshore accounts

123 million accounts reported across borders in one year. The gap offshore once offered is a reporting schedule now.

Built to

Hold wealth under a different rulebook, where cooperation between states was slow.

Addressable today · Running

The US Foreign Account Tax Compliance Act (2010) and the OECD Common Reporting Standard require financial institutions to report accounts held by foreign residents to their home tax authorities. In 2022 alone, 123 million accounts holding about €12 trillion were exchanged.3 Since September 2023 the IRS has used machine learning to select large partnerships for audit.4

Extrapolation

The annual exchange becomes continuous matching: reported balances checked against declared income by machine, before anyone opens a file.

Verdict

The gap offshore once offered is a reporting calendar now.

Sources

Checked September 29, 2026.

  1. 3Wikipedia, citing the OECD: Exchange of information (CRS statistics)
  2. 4Kirkland & Ellis: IRS to use AI to select partnerships for audit (September 2023)