tag:blogger.com,1999:blog-4622776924781844427.post8211416574064422939..comments2024-03-23T13:43:27.051-04:00Comments on Tax, Society & Culture: Transfer pricing: Neither Science nor LawAllisonhttp://www.blogger.com/profile/16733465339926078146noreply@blogger.comBlogger2125tag:blogger.com,1999:blog-4622776924781844427.post-31748604826190305592012-06-25T22:41:35.749-04:002012-06-25T22:41:35.749-04:00I actually forgot in my previous post to give the ...I actually forgot in my previous post to give the actual link.<br /><br />http://extranet.isnie.org/uploads/isnie2012/cockfield.doc<br /><br />He actually was interviewed in a recent Montreal Gazette article and in fact didn't speak all that well of the existing OECD information sharing model.<br /><br />But since the agreements are so novel, Queen's University tax law professor Arthur Cockfield said it is yet to be seen if there will be any real impact, especially since agreements to share info are useless if the country in question doesn't collect info.<br /><br /><br />"I am skeptical that these TIEAs will bring in many revenues to Canada," Mr. Cockfield said. "Part of the problem is that, again, these tax havens don't have income tax systems, so the governments and even the banks don't keep the same kinds of records that our banks do."<br /><br /><br />But Mr. Cockfield said multilateral agreements are preferential to unilateral laws that impose obligations on other nations, such as the U.S.-proposed Foreign Account Tax Compliance Act, which has received criticism in Canada.<br /><br /><br />"I believe it's an illegal attempt to access tax information from Canadians. It doesn't comply with the Canada-U.S. tax treaty and it doesn't comply with the American obligations under NAFTA," he said.<br /><br />http://www.montrealgazette.com/mobile/business/fp-business/cheats+finding+fewer+havens/6798181/story.htmlTimhttps://www.blogger.com/profile/03894651289037073128noreply@blogger.comtag:blogger.com,1999:blog-4622776924781844427.post-41635396871796859512012-06-25T22:00:04.639-04:002012-06-25T22:00:04.639-04:00Just to let you know Arthur Cockfield of Queens...Just to let you know Arthur Cockfield of Queens's University has a new working paper that references your work in several places. I do have note that Cockfield (a previous FATCA critic) spends about half the paper crictising FATCA. I wonder how that must of gone when he presented at the USC School of Law last week. One of my dreams is to get Cockfield on stage together with someone like Itai Greenberg or J. Richard Harvey to debate the issue. Cockfield seems to be the most prominent critics of FATCA outside of some bank secrecy "dead enders." I don't think at all Cockfield is a "bank secrecy" supporter in face he is anything but.Timhttps://www.blogger.com/profile/03894651289037073128noreply@blogger.com