I actually had the chance to advise the government, the advisory panel on Canada's system of international taxation, two years ago on this issue. The interesting thing about TIEAs, tax information exchange agreements--and none of them are in force yet. We've negotiated them, but to my knowledge none of them are currently working. The jury is still out. Our government, in 2007, decided to negotiate these not to fight international tax evasion but because at that time they had passed a tax rule to inhibit something called double-dip financing. We needed to trace interest payments to tax haven countries. It wasn't to attack the tax evasion problem. Nevertheless I think it is a helpful reform.
I am somewhat cynical. I don't think it will help too much. There are a number of reasons why tax scholars are suspicious that it won't help. Those TIEAs are to be distinguished from our Barbadian treaty. Since the 1970s, we have had a full-blown tax treaty with Barbados that includes an exchange of information provision in it. So it's not a TIEA.
Previously governments, such as that of Switzerland or the Cayman Islands, would share information with us only if there was an allegation of criminality or fraud. The TIEAs don't require that. That's no defence. They have to share the information even if it's just regular old tax avoidance or there's no allegation of fraud.
These are positive developments, but I still don't think we'll see meaningful sharing.