Finance committee  I would have to look at that a little bit more closely. I think that plays with the question of who is a U.S. person for U.S. tax purposes. My understanding of the definition in the Internal Revenue Code is that it's very, very broad. As Mr. Cockfield talked about, that includes

Finance committee  And on the compliance side, I don't know, but I would suspect that, as I said, the definition of a U.S. person is very broad under the Internal Revenue Code.

Finance committee  That is on the compliance side. To be clear, that's not a cause of FATCA. That is a U.S. tax problem under the Internal Revenue Code, and the way that the Internal Revenue Code classifies tax-free savings accounts. The only issue with FATCA is the amount of information being r

Finance committee  I think the answer to the first question is no. I think that most people learn of their U.S. tax obligations from the newspaper. The United States has a very extensive consulate network in Canada, both a well-staffed embassy and a well-staffed consulate network outside of Ottawa.

Finance committee  I am somewhat familiar with the work that the OECD is doing, and my understanding is that they are sort of using FATCA as a model for a series of what I understand to be bilateral agreements between different tax information-sharing agreements. So I am sort of familiar with that.

Finance committee  Yes. I thought I made that clear in my statement that the issue is not one of FATCA being--

Finance committee  Yes, that's correct.

Finance committee  I don't think it would be a legislative decision.

Finance committee  For example, on the tax-free savings account, an administrative bulletin from the IRS might be likely—

Finance committee  My answer is that it could be done by the IRS, and it is not a piece of legislation that would be required.

Finance committee  An amendment to the treaty would be—

Finance committee  Yes, thank you. It has refused U.S. persons as customers. Some Swiss banks are the same. The government should include a non-discrimination clause in the IGA so that U.S. citizens cannot be disadvantaged from accessing financial services. The solution to all of this, I think,

Finance committee  Good afternoon, can you hear me?

Finance committee  Thank you very much for the invitation to be appear before you. I just want to say at the outset that my views are my own and are not associated with my employer. I'm a Canadian-trained lawyer and I currently practice U.S. tax law at White&Case LLP, an international law firm