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After earning a US$104-million whistleblower award for tipping off American authorities, Birkenfeld spent two-and-a-half years in prison after being convicted of fraud for withholding information about a client. Birkenfeld disputes the charge.

Not everyone is impressed by Birkenfeld’s persistence. David Sohmer, a tax lawyer and a founding partner of Spiegel Sohmer Inc., said the majority of the UBS clients Birkenfeld knew about have likely already come forward to the CRA. Sohmer suggested the whistleblower is chiefly interested in publicity for his recently published book.

“There’s nothing he’s going to teach by way of a PowerPoint. He’s going to give a Grade 1 talk to the politicians?” Sohmer said. “Birkenfeld has no information today that is of any material value to Canada.”

Birkenfeld disputes that, saying he has many documents that have not been made public and knows former colleagues at UBS who would be willing to come forward as witnesses if Canada decided to open a criminal investigation.

He said his refusal to let the issue go has nothing to do with self-publicity or the pursuit of additional whistleblower awards — which he isn’t eligible for in Canada anyway, because of his felony conviction.

“I’ve got enough money,” Birkenfeld said. “It’s the right thing to do.”

Sohmer disagrees that the penalties Birkenfeld is pushing for are the right thing to do. He said the Canadian method of coaxing tax evaders into voluntary disclosures by promising to waive harsh penalties is much more effective at recovering taxes than dramatic raids and threats of incarceration.