1) The treaty is clearly one-sided, designed for the US government to obtain information from the Panamanian financial system about US taxpayers, not the other way around;
2) the requesting party (i.e. US government) does not need to provide detail on the targets of its requests;
3) the requesting party does not even need to have an immediate use for the information being requested, such as an imminent lawsuit or criminal tax investigation;
4) information about beneficial ownership of corporations and foundations is also fair game;
5) the sharing of information is retroactive– they can request information from years ago as long as the records exist.