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ISBN: 9781552214305

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International Tax Evasion in the Global Information Age

International Tax Evasion in the Global Information Age provides the most comprehensive analysis of the OECD’s and Canada’s war on offshore tax evasion and offers a timely and valuable explanation of the policies and technical rules behind the new laws governing the global exchange of taxpayer information. This book provides indispensible legal information and analysis for the global financial community, professionals serving the wealth management industry, and policy-makers alike.


David Kerzner

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.

Chapter Title Abstract Contributors Pages Year Price


The book is intended to assist professionals in the banking, financial, legal, tax and accounting sectors to grasp a technical understanding of international tax information exchange agreements. ; 3 $0.30


Overview of the problem of offshore tax evasion and review of recent events in international financial crime. ; 28 $2.80


Examination of basic concepts in international tax law, principal theories in international tax policy, and the role of tax treaties. ; 18 $1.80


Examination of the relationship between exchange of information mechanisms and the goals of international tax law in addressing the threat of tax havens and preferential tax regimes. ; 45 $4.50


Examination of powers and tools that the Canada Revenue Agency uses to obtain taxpayer information for an audit, whether for civil or criminal purposes, particularly in non-voluntary situations. ; 42 $4.20


Review of powers of the United States government to obtain foreign-based information about its taxpayers. ; 46 $4.60


Examination of the role of Canada’s tax information exchange agreements in the exchange of information with foreign jurisdictions. ; 44 $4.40


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 … ; 22 $2.20


Overview of the automatic exchange of information, as distinguished from spontaneous exchange and exchange upon request, arising from the systematic and periodic transmission of bulk taxpayer … ; 26 $2.60


Examination of the Foreign Account Tax Compliance Act of the United States. ; 33 $3.30


Overview of the voluntary disclosure process in Canada and the United States. ; 35 $3.50


Conclusions regarding the effectiveness of tax exchange information agreements and recommendations for changes to tax policy to combat international tax evasion. ; 16 $1.60