Steven Dean (Brooklyn) has published The Incomplete Global Market for Tax Information, 49 B.C. L. Rev. 605 (2008). Here is the abstract:

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 therefore made the ability to acquire useful extraterritorial tax information more important than ever. To make the income tax function effectively 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 (i) to promote a supranational effort like the E.U. Savings Directive to facilitate cross-border flows of tax information, (ii) to unilaterally reduce its dependence on extraterritorial tax information or (iii) 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 80-year-old barter method in use today.