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Finance committee  Thank you, Mr. Chairman. I appreciate the opportunity to return to this. Yes, I think the example you give of a Canadian bank owning a U.S. financial institution is an excellent one. U.S. tax rates are at or are increasingly above Canadian tax rates, and that may mean that the a

December 13th, 2010Committee meeting

Brian Ernewein

Finance committee  Forgive me, Chairman. Do you mean how we feel about an amnesty or how we feel about voluntary disclosure, or...?

December 13th, 2010Committee meeting

Brian Ernewein

Finance committee  I think the policy has been in place since at least 1938, so it does predate this government. The main point is that I don't believe it is tax avoided. It's the application of Canadian laws to say that foreign companies owned by Canadians won't be taxable in Canada simply becau

December 13th, 2010Committee meeting

Brian Ernewein

Finance committee  That's what I had suggested earlier as a concern. There are considerations going the other way, that you can try to bring people back into the system, and that's helpful, too. But certainly one of the objections or concerns with having an amnesty is that yes, it would reward the

December 13th, 2010Committee meeting

Brian Ernewein

Finance committee  Actually, the suggestion was made that it comes from the U.S. treasury, but I don't know, so I can't confirm that.

December 13th, 2010Committee meeting

Brian Ernewein

Finance committee  I don't want to characterize it as a waste of time, but I think it would be a very difficult exercise. The number of assumptions one would have to make to arrive at a number would make the exercise perhaps of less utility than one would hope.

December 13th, 2010Committee meeting

Brian Ernewein

Finance committee  Thank you. I'll just take a moment to elaborate a little bit on what we have in the international context. There are obviously others that apply domestically. There have been foreign reporting rules that have been in place for a number of years and these are not, as I said earl

December 13th, 2010Committee meeting

Brian Ernewein

Finance committee  Thank you very much for the question. I appreciate the opportunity to come back to this, because I think it's an important point. First, if I've given the impression that I thought we didn't have information relating to our banks, I didn't mean to say that. I don't believe that'

December 13th, 2010Committee meeting

Brian Ernewein

Finance committee  I have a comment--hopefully it's responsive--to add to my colleague's comments. The idea of an amnesty is not patently unreasonable; I don't think anyone is suggesting that. But there are incentives it incorporates that give us pause. Functionally it's a reward for non-complian

December 13th, 2010Committee meeting

Brian Ernewein

Finance committee  I will say that the committee has considered that question before, and I'm happy to attend again. I'm happy to offer a couple of observations today on that, if the committee is interested, to explain what I thought was the concern with that, but just to make note of the fact that

December 13th, 2010Committee meeting

Brian Ernewein

Finance committee  Perhaps. I don't have a ready answer for that. I will make the observation that I think there's probably a lot of overlap in the criteria we'd apply, in terms of having both lots of economic interaction, diplomatic relations as a threshold question, and the like.

December 13th, 2010Committee meeting

Brian Ernewein

Finance committee  A brief response is that I certainly appreciate the concern. I don't think there's a direct linkage between that and the exchange of tax information. Indeed we're pretty concerned about tax information being provided to other countries for the sake of making assessments of tax

December 13th, 2010Committee meeting

Brian Ernewein

Finance committee  I think their proximity to the U.K. is important, and to Europe as well. Speaking personally, I've learned a little bit of geography as a result of this, and some of the smaller islands in the South Pacific are new to me, but it is true that you don't have to have a vast land mas

December 13th, 2010Committee meeting

Brian Ernewein

Finance committee  That's a fair question, and it's certainly the case that we do want to be attentive to the system we've got in place to essentially help CRA in its ability to enforce Canada's laws. First and foremost, I'd say Canada has a self-assessment system. For the most part, honest Canad

December 13th, 2010Committee meeting

Brian Ernewein

Finance committee  I think some of the countries felt it was a bit undiplomatic that others were pressing them to agree to things such as this on greater exchange of information. There were from time to time many assertions of each country's own sovereignty and objections to being pushed or pressur

December 13th, 2010Committee meeting

Brian Ernewein