In most countries in the world, residence is the primary basis of taxation – see Tax residence.
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The Philippines took steps to remove itself from the blacklist and Malaysian Prime Minister Najib Razak had suggested earlier that Malaysia should not be in the bottom tier.
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Noted jurist and former law minister Ram Jethmalani along with many other well known citizens filed a Writ Petition (Civil) No. 176 of 2009 in the Supreme Court of India seeking the court's directions to help bring back black money stashed in tax havens abroad and initiate efforts to strengthen the governance framework to prevent further creation of black money.
Apex Silver Mines, founded by Thomas Kaplan, from Denver, Colorado was a US-American transnational mining corporation with a tax haven address in the Cayman Islands.
In 2009 the White House issued a press release in which the Netherlands were mentioned as tax haven.