Yes, sir.
The first thing I'd like to point out is that we already have automatic information exchange between Canada and the United States with respect to cross-border portfolio interest income. If I open a bank account in New York City at the Bank of America, they report this automatically to the IRS, and the IRS exchanges this information automatically with the CRA.
There are dozens of examples of these automatic information exchange processes around the world. This is yet another problem with FATCA. It doesn't account for the fact that we have this enhanced cooperative measure already in place between Canada and the United States.
Having said all that, to respond to your question, I think some of the principles behind FATCA could be imported to a broader multilateral agreement—again, automatic information exchange. Also, importantly, we'd have to have a system to ensure that taxpayer identification numbers were relatable by each country; in other words, you can tie the income to an actual human being. Combine that with protections for taxpayer rights, traditional protections offered under Canadian law, and I think that would be a very good idea.
I outline some of this in a 2001 article in Minnesota Law Review.
Thank you.
