Article 26 of the OECD Model Tax Convention on Income and on Capital
Explanation of the article in the Model Tax Treaty that contains the rules governing exchange of information between two contracting states, including foreseeable relevance, privacy rights, and limitations on providing information.
David Kerzner, LLB (Queen’s University), LLM (Int Legal Studies) (NYU), LLM (Tax) (NYU), PhD (Law) (Queen’s University), is a US and cross-border tax lawyer in private practice in Toronto. David has over twenty-four years of experience in designing and implementing cross-border tax and legal solutions for companies, funds, and individuals. David is admitted to practice in the State of New York and the Province of Ontario, and is a Solicitor of the Senior Courts of England and Wales. Among other published books, David is the editor-in-chief and principal co-author of The Tax Advisor’s Guide to the Canada-U.S. Tax Treaty, a two-volume loose-leaf service, and the co-author of The Manager’s Guide to International Tax. He is a fellow in the Taxation Law & Policy Research Group at the Monash Business School at Monash University. David has served honourably in the US Navy Chaplain’s Corps in the US Marine Corps Forces (Reserve).
David W. Chodikoff
David W. Chodikoff, BA (Spec Hons) (York), MA (Dalhousie), LLB (Dalhousie), specializes in tax litigation (civil and criminal). He is the national tax litigation lead and a partner at Miller Thomson LLP. David was a former counsel and a Crown prosecutor at the Department of Justice (Canada). He has over 100 reported decisions and has conducted more than 550 cases before the courts in Canada. In 2013, David was selected as one of the leading tax controversy advisors in the world and was included in the International Tax Review’s “Tax Controversy Leaders Guide of 2013.” David has edited and contributed to six tax publications, including Tax Litigation, 2d ed, a multi-jurisdictional comparison of the subject in thirty countries. David is the recipient of numerous national and international awards. David is in Martindale-Hubbell and is AV Preeminent® Rated.