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39 Int'l Tax J. 1 (2013)

handle is hein.journals/intaxjo39 and id is 1 raw text is: SUSTAINABLE Certified Sourcing FORESTRY INITIATIVE wvw.sfiprogram.org SFI 00453 N NAJ~ r CCH Journals and Newsletters Emall Alert for the Current Issue Sign Up Here... CCHGroup.com/EmaiL/journals 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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