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The United States finds itself facing a growing disparity between the tax information it collects domestically and the tax information it is able to acquire from abroad. At the same time, globalization and technology have made it easier for taxpayers to ignore national borders and have therefore made the ability to acquire useful extraterritorial tax information more important than ever. To make the income tax effective in today's borderless economy, the United States must abandon the antiquated notion of information exchange. Creating a more complete market— one more likely to facilitate efficient transactions than today's barter market in extraterritorial tax information—is one possible remedy. The United States could also choose (1) to promote a supranational effort like the European Union Savings Directive to facilitate cross-border flows of tax information, (2) to reduce unilaterally its dependence on extraterritorial tax information, or (3) to pursue all of these possibilities simultaneously. Any of those strategies would be more likely to ensure that the United States receives the extraterritorial tax information it needs than the eighty-year-old barter method in use today.


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6 Sep 2022
3.68 MB



  • Subject
    • International Law

    • Taxation-Federal

  • Journal title
    • Boston College Law Review

  • Volume
    • 49

  • Issue
    • 3

  • Pagination
    • 605

  • Date submitted

    6 September 2022