A number of commentators have suggested an increase in the scope of bilateral information
treaties to provide for regular and automatic exchanges of information. This would require the
U.S. banks to increase their collection of information.
Avi-Yonah and Avid-Yonah and Guttentag suggest adopting the model OECD bilateral Tax
Information Exchange Agreement (TIEA ). This information exchange would relate to civil as
well as criminal issues, it would not require suspicion of a crime other than tax evasion, and
would override tax haven bank secrecy laws. Non-tax havens could be induced to make such
agreements to obtain information, and thus, such a change would require collection of
information on interest payments by banks and financial institutions. Treasury has proposed only
16 countries, but Avi-Yonah and Guttenberg suggest no reason to restrict the provision in this
way. Treasury could use existing authority not to exchange information that might be misused by
non-democratic foreign governments.