https://repository.law.umich.edu/law_econ_current/95/
"IGAs vs. MAATM: Has Tax Bilateralism Outlived Its Usefulness?" by Reuven S. Avi-Yonah and Gil Savir
The main concern about the IGAs is that they enshrine the bilateral model of tax information exchange that has dominated the 20th century. Unfortunately, there...