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BERLIN — After the New York Times reported Sunday that President Trump had paid no federal income tax for years and made nominal payments in 2016 and 2017, while accruing mammoth debts, the verdict from abroad was damning.

Trump’s apparent tax avoidance was “obscene,” said an editorial in Sueddeutsche Zeitung, Germany’s paper of record. The president “misled an entire nation,” Poland’s Gazeta Wyborcza newspaper inveighed. It was clear, the paper wrote, why Trump had broken with custom and refused to release the tax returns himself.

During the presidential debate on Tuesday, Trump, who often cites his experience as a billionaire businessman as a reason to lend him support, said he paid “millions of dollars” each year, but he has not produced evidence of that. In 2017, he paid more taxes in Panama, India and the Philippines than in the United States, where he used losses to claim breaks and refunds, according to the New York Times. Democratic presidential nominee Joe Biden and his wife, Jill, meanwhile, reported paying a 31 percent federal income tax rate last year, according to returns they released Tuesday.

Trump’s returns, and his attempts to avoid revealing them, have attracted attention around the world. But he is hardly the only world leader to keep his tax information private. German Chancellor Angela Merkel has not released her tax records. And when Germans go to the polls next year to elect her successor, they probably won’t have seen the tax returns of those candidates either.

In most of the world, the tax records of politicians are off-limits to the public.

Why, then, is Trump the subject of particular scrutiny? Much of the frustration appears to stem from what Human Rights Watch researcher Sarah Saadoun described last year as “the Trump administration’s long record of retreating from America’s bipartisan role as a leader in the fight against global corruption.”

Around the world, the United States was long seen as the primary role model for anti-corruption advocates pushing for transparency both expected and required for those seeking political office, a reputation dating back decades.

Fury over the Watergate scandal, which led to the resignation of President Richard Nixon in 1974, along with other high-profile ethics violations, resulted in the implementation of unprecedented rules that allowed extensive scrutiny of public officials’ finances, formalized in the Ethics in Government Act of 1978.

Even though the idea of forcing public officeholders to submit details of their finances has since made deep inroads in Western Europe, the “early — and even to a great extent, the current — West European disclosure regimes did not match the U.S. system in terms of complexity, the range of officials or enforcement mechanisms,” an OECD report found in 2011.

Top officials across numerous agencies are required to submit their tax returns to Senate committees.

But the most evident manifestation of the more transparent U.S. approach has been the custom, observed by every president since Nixon, of voluntarily publishing at least some tax returns or summaries. The idea that the public should have access to such information to help “keep their officials in check,” said Valts Kalnins, an anti-corruption researcher in Latvia, is still mostly associated with the United States, from where it spread.

In Europe, only Scandinavian and, to some extent, Baltic countries have matched that level of public scrutiny. Any Norwegian can access the tax records of their neighbors, colleagues or prime minister under rules that predate those in the United States. But Norway also has one of the world’s most equal income distributions, making its approach difficult to emulate.

After the fall of the Soviet Union in the 1990s, some countries in the region began to see the U.S. and Scandinavian approaches as possible tools against spiraling corruption. In Latvia, the income of any public official — whether police officers or prime ministers — is publicly available, though such access is limited to officials’ time in office, said Kalnins. The Latvian approach is meant to deter corruption, but it’s ill-equipped to inform the public about past wrongdoing or ethically questionable behavior, he said.

In most other countries, leaders face even fewer legal requirements that they make their financial records available, despite growing international pressure to reveal more details. After the 2016 publication of the Panama Papers — documents that revealed secret offshore holdings, including those of several world leaders — then-British Prime Minister David Cameron released six years of tax data amid questions about whether he profited from an offshore fund set up by his late father.

In Britain, the release of tax information is still subject to the whims of politicians, who are not required by rules or norms to do so. Neither of Cameron’s successors — Theresa May and Boris Johnson — opted to release their full or latest taxes upon assuming office, once the fallout of the Panama Papers and a parliamentary expenses scandal had begun to fade from the news. (As mayor of London, Johnson released a summary of some of his tax returns in 2016 and called on members of Parliament to do the same. May had published a summary of her taxes in 2016, too.)

The mere existence of a legal obligation to release tax or income details, however, doesn’t preclude the possibility of fraud or corruption. While Argentina has one of South America’s strictest asset-reporting requirements, the strength of such mechanisms rises and falls with the rule of law.

Despite facing dozens of charges of embezzlement, money laundering and bribery that date back to her presidency, former president Cristina Fernández de Kirchner made a political comeback as vice president last year.

Meanwhile, in Nigeria, former president Goodluck Jonathan outright refused to declare his assets while in office, even though he was obliged to do so, according to Transparency International, an anti-corruption NGO.

Some countries have in recent years moved toward greater public and judicial scrutiny of their leaders, often enacting reforms in the wake of embarrassing scandals, as the United States did. After the French budget minister had to resign over tax fraud accusations in 2013, a cornered President François Hollande launched one of the most ambitious initiatives in recent years, establishing France’s High Authority for the Transparency of Public Life (HATVP).

The independent ethics body monitors potential conflicts of interest among more than 15,000 politicians and civil servants and publishes their self-declarations.

But a European monitoring group concluded last year that the ethics body was not equipped with sufficient authority. And while the body publishes declarations of assets by all presidential candidates before the elections, the authorities’ scope is more limited once a president has taken office and enjoys immunity throughout his or her term, said Elsa Foucraut, a French researcher with Transparency International.

Some anti-corruption advocates have maintained that because of such limitations, calls for voluntary transparency from politicians — similar to what’s been the norm in the United States — should remain the goal.

Before the Trump presidency, the United States was the primary success case for that approach.

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