Where the U.S. was ultimately going and where they ended up was with something called the Foreign Account Tax Compliance Act, which is something they passed into law and it creates all manner of challenges for individuals and institutions internationally.
With that legislation what they want to do is assess a 30% withholding tax on all U.S. source income flowing to or through financial institutions anywhere in the world, unless they provide information directly to the IRS on U.S. persons who hold an account anywhere in the world with that institution.
The challenge with something like that is that it invariably ends up in a conflict of laws. The reason it ends up in a conflict of laws is that privacy legislation in Canada, as much as anywhere else, is predicated on the fact that I can only collect information that I need here to do my business. I have to get consent when I collect it, and I have to give consent when I provide it. And the only real exceptions to that are domestic, largely. Obviously there are arrangements made with CRA so the information can be sent to CRA on tax information of clients.
May I continue?