The Millards moved to the Northern Mariana Islands (the “Commonwealth”) in 1986 because of a tax incentive designed to encourage US citizen migration to that jurisdiction. In 1987 they sold their interest in a computer business for US$76.8 million and filed US tax returns and paid approximately US$4.7 million in taxes. They were soon after notified that the Commonwealth considered that tax payment to be insufficient, but, at least as the Millards submitted, the Commonwealth subsequently accepted their position (a point still disputed by the Commonwealth). In 1990 the Millards left the Commonwealth and moved to the Cayman Islands. In 1994, the Commonwealth obtained judgments (in their own jurisdiction) in default of defence against the Millards in the amount of US$36 million, which, because of interest, has now increased to approximately US$123 million.