The Department of Finance's files on the 1993 tax amnesty contain memoranda to Government, referring to bogus non-resident accounts. The first memorandum states:
"There is currently approx £4 billion on deposit in accounts designated `non-resident'. It is likely that a very high proportion of these accounts have been fraudulently designated and that the depositors are resident.
"They may account for 50 per cent or more of the total amount on deposit. In the run-up to the introduction of DIRT the number of non-resident accounts trebled."
In response, another official wrote:
" . . . the main problems we have are lack of hard information and the likely repercussion of any major moves against the banks in this area."
