Efromovich used a Panamanian offshore that hid more than 20 firms located in tax havens. Corporate tax havens often serve as "conduits" to traditional tax havens. Privacy and secrecy were established as an important aspect of European tax havens. Political parties have different agendas in respect to tax havens. U.S. citizens therefore find it difficult to take advantage of personal tax havens. There were allegations on him that he transferred to tax havens. Ireland is one of the world's largest corporate tax havens. There is evidence Ireland meets the captured state criteria for tax havens. Since 2010, academics consider OFCs synonymous with tax havens. The 1998 OECD definition is most frequently invoked by the "OECD tax havens". The Council of Europe also decided to issue reports naming tax havens. Zucman's papers are some of the most cited papers on research into tax havens. The report also includes criticisms of Bank of America's use of tax havens. The corporate tax havens, including Ireland, opted out of the key Article 12. Most estimates have wide ranges (see financial effect of tax havens).