Finance committee  I agree with Mr. Sohmer. I think from my seat across the border, Canada seems to have been quite active and effective in promoting multilateral efforts on exchange of information and tax enforcement.

Finance committee  Well, that's a good question. In fact, a number of practitioners have been talking to the IRS about the possibility of adopting a second settlement initiative. I actually received an e-mail from a colleague today that there was some rumour that it might even be announced by the

Finance committee  I've always thought that tax enforcement pays for itself and then some. Obviously, the government has many budgetary needs. What happened in the United States 20 years ago or so is the IRS became a punching bag politically and took some unfair criticism. And the IRS retrenched it

Finance committee  Greed.

Finance committee  I can speak to the United States, and Mr. Sohmer can speak to Canada. The U.S. approach was to require a taxpayer to pay six years' worth of tax and interest and a surcharge penalty on the tax on the income earned in the foreign accounts, plus 20% of the highest balance in the a

Finance committee  In addition to the U.S. initiative in 2009, a lot of other countries have adopted amnesty or quasi-amnesty programs relating to foreign accounts. The U.K. has done so. Italy has done so. I believe France has done so. Some of these programs have been wildly successful. I cannot r

Finance committee  The primary reporting requirement in the United States is both on the tax return and on a separate form called an FBAR, a Foreign Bank Account Report. It's a special treasury department form. Until three or four years ago, very few people knew that this form existed. It had been

Finance committee  In part, that's right. I think FATCA is perceived as an overarching legislative fix to a lot of perceived loopholes that people might be able to use to skirt the information reporting requirements.

Finance committee  The Foreign Account Tax Compliance Act.

Finance committee  It has not yet taken effect. Significant portions of it don't come into effect until 2013. And financial institutions like HSBC and others are struggling with a fairly significant compliance burden to implement it. The IRS has issued one set of guidance on implementation, but the

Finance committee  Yes, I think any effective tax policy has got to have a mechanism for people who have cheated to come in and make things right. We may not like the fact that people cheat, and we may do our best to try to deter them from doing so. But there's an expression that the only two cert

Finance committee  There's a debate in the United States over just how successful this IRS program was. I happen to be of the view that, notwithstanding some of the procedural and bureaucratic difficulties, from a macro perspective it was enormously successful. Over 30 years of practice, before th

Finance committee  That particular strategy, at least in the U.S., has been trumped by this Foreign Account Tax Compliance Act. And believe me, I'm not a proponent of this legislation. I think it's incredibly burdensome in many respects. But the U.S. Congress came up with a way that they hope will

Finance committee  When a taxpayer comes to us to initiate a voluntary disclosure, it's important that we quickly gather their banking information so we know exactly how much previously unreported income they now need to report. And we need to identify them to the Internal Revenue Service as quickl

Finance committee  Banks are now providing clients with documents that instruct them on their reporting responsibilities. I had not seen this until the last year or two, but I have now seen American clients who receive forms from banks. These forms specifically direct them that they must report the