Emily Wang (J.D. 2012, Hastings), Note, The Opaque Future of Tax Information Sharing Between the United States and China: An Analysis of Bank Secrecy Laws and the Likelihood of Entrance Into a Tax Information Exchange Agreement, 35 Hastings Int'l & Comp. L. Rev. 411 (2012):

This Note will first explain how offshore accounts make tax evasion possible and the significant role of domestic bank secrecy laws in facilitating tax evasion in the United States and China. Next, it will introduce the Tax Information Exchange Agreement proposed by the OECD and its past and current efforts to increase global tax information sharing. Lastly, it will conclude by exploring how despite the current offshore tax evasion crisis occurring between these two countries, the Tax Information Exchange Agreement is an ineffective mechanism and will neither truly eliminate tax evasion.