The Role of Canada’s Tax Information Exchange Agreements in the Fight against Offshore Tax Evasion

Abstract

This chapter begins by reviewing the policy objectives behind tax information exchange agreements (TIEAs), while giving particular consideration to the objectives set by the OECD. The goals of Canada and the United States with respect to TIEAs are also reviewed. This chapter then examines how Canada’s TIEAs function as vehicles for the exchange of information (EOI) between Canada and foreign jurisdictions. Select articles dealing with the EOI process in Canada’s TIEAs are described and then compared against (1) the OECD Agreement on Exchange of Information on Tax Matters, (2) each other (i.e., other Canadian TIEAs in force), and (3) the TIEA between the United States and the Cayman Islands. The US–Caymans TIEA is used as an example of a US TIEA because of the Cayman Islands’ ongoing high-profile as a tax haven. By looking at Professor Steven Dean’s analysis of tax harmonization versus tax deharmonization, this chapter examines an important overarching question in the debate on effective EOI and the use of TIEAs regarding the global community’s focus on achieving a victory against international tax evasion through cooperation around the implementation of a uniform set of rules and procedures. The conclusion provides a summary of the results of the comparative analysis.