As for the offshore thing…well, except in the most doubly-egregious cases (that is, egregious sums coupled with egregious stupidity by the tax nonpayer) it’s hard to prove in court that a particular action was tax fraud.

Note that the article says “convicted”. Assuming it’s using terminology correctly, that means a criminal conviction for tax fraud, which requires proof of _specific intent to commit a federal crime_ to the same standards as any other criminal conviction. Merely disallowing a practice and assessing back taxes and penalties is both far easier and far more common. 68 criminal convictions per year for specifically offshore-related fraud is easy to believe, because the majority of problems with questionable offshore transactions will never result in a criminal prosecution, let alone a conviction. (The IRS wants your _money_. And they can take it much easier by administrative means than they can by trying to send you to prison. They generally only go to criminal court with people whose behavior is so flagrant and fraudulent that the government feels a need to make public examples of them. But only those “public examples” would be included in the statistics for convictions.)