Finance committee  Again, Canada does not have the leverage, the economic muscle, to force UBS to provide a list of clients. In fact, the arrangement that the United States had with Switzerland was within the context of the existing United States-Switzerland tax treaty, which provided for an exchange of information relating to matters characterized as tax fraud rather than tax evasion.

Finance committee  From UBS.

Finance committee  Well, we have sent in.... Part of the material I have is an extensive brief that we sent to the Quebec authorities. I'll give you one small example. We have clients who in 1946, after having survived the Holocaust in Hungary, moved to Mexico and in 1993, at age 73, moved to Canada.

Finance committee  I wish you could tell me how. In Quebec politics, the Liberals are not terribly popular, and the PQ....

Finance committee  I think Canada has done a marvellous job in the international arena. Again, its powers are limited. It would have liked to have seen an automatic exchange-of-information provision provided for in the treaties, but the G-20 turned that down, and the TIEAs and the protocol to the Canada-Swiss tax treaty and the international standard have limits now.

Finance committee  Well, the problem with Canada's going after UBS is the problem of a population of 33 million versus a population of 330 million. UBS operations in Canada are not significant. Between UBS AG—the branch—and UBS, the actual bank carrying on business here, I think total assets are probably in the $2 billion range.

Finance committee  We have a program in Canada, the CRA has, for doing what's called a net worth audit. You take a look at the net worth at the beginning of a period, the net worth at the end of the period, calculate what living expenses are, and see what you've declared. It's a fairly effective program.

Finance committee  I'm not sure it's a matter of education. I think firstly we have to realize that Canada has limited ability to take unilateral action. If we tell the Swiss that unless they force their banks to disclose information, we're going to prohibit Swiss from investing in Canada or lending to Canada, we're simply shooting ourselves in the foot.

Finance committee  It's greed.

Finance committee  I can tell you that if they were west of the Quebec border, or east of the Quebec border, given current CRA policy, I would tell them, without any compunction, “Send in your voluntary disclosure. Let's get this done quickly. The practice of the CRA now is perfectly compatible with a proper voluntary disclosure program.”

Finance committee  Is this addressed to me?

Finance committee  I think you have to make a distinction between hoodlums and the elderly. Hoodlums will always find a way to beat the system. It's becoming more difficult with--

Finance committee  Oh, there are a number of reasons, obviously.

Finance committee  Not to pay taxes; security; if you--

Finance committee  --so I brought it down to $100 billion, and I compared that against the yardstick of the $5.6 billion that apparently Canadians have with UBS, which made it sound reasonable. So I figure there's $100 billion, and I would guess, based on my experience, that there is $20 billion or $30 billion that could be repatriated very, very quickly.