I think that's an important question. My big concern is—and we've heard a lot of discussion this morning about what is in the bank's records about who owns an account, where it's owned, and who the owner of a corporation is. The big problem we have is that that information is in the bank's files and it isn't available to a tax authority, or if it's available, there's considerable difficulty.
Speaking purely practically, we also heard about the problem CRA has with checking information supplied to it. Once we come down to, for example, sending portfolio investment information from the States to Canada, let alone from the rest of the world to Canada, we are talking about massive amounts of information.
My recommendation is that we make this as simple as possible. The desire is not to check every tax return or every record; that's impossible. What we want to create is a deterrent effect. So we need to have the information exchange that creates maximum deterrence at a minimum cost, minimum risk, to privacy. That would be disclosure of who the warm bodies are—the real human beings who have interests in an offshore bank account, an offshore trust, an offshore company—to the territory where they are a tax resident.
As I say, I'm not interested in disclosure of the amount of income. There's risk in that information exchange, but it will give the domestic tax authority, the CRA, the right to say that you aren’t disclosing an offshore source of income on your tax return; we're told you have an interest in this bank account in Jersey, the Isle of Man, Cayman—wherever—and we want to ask you to explain that.
It also makes the tax information exchange agreement work, because suddenly there is the smoking gun to make an inquiry, which is completely absent and it makes them impossible to use at present.
That minimal exchange would make the whole international system work and create the deterrent effect, which I believe could be exploited to improve taxpayer morale and the belief that everyone is going to be paying, which is essential to a proper outcome of this.