39 Int'l Tax J. 1 (2013)

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Vol. 39, No. 1 January-February 2013

A NOTE FROM THE EDITOR-IN-CHIEF

Tax-Efficient Foreign
By Lowell D. Yoder

IP Strucutures

ARTICLES

Tax Base Defense: Time to Update the Model Treaties?
By Cym Lowell and Bret Wells
IRS Introduces Two Unique Remedies for U.S. Persons
with Unreported Canadian Retirement Plans and Accounts
By Hale E. Sheppard, Esq.
One Size Does Not Fit All: Unintended Consequences
of the Offshore Voluntary Disclosure Program
By Matthew A. Morris
Tax Audit and Investigation in China and Hong Kong
By Samuel Chan, Gerald Chau and Patrick Leung

CONFERENCES

2

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