Thank you.
This is purely an information agreement, so it's about collecting information from financial institutions and providing that information through the Canada Revenue Agency to the IRS.
As to what systems and collection provisions we have with the United States, there is such a provision. For the last 15 or 18 years, perhaps, in the Canada-U.S. treaty, there has been provision in that treaty for Canada and the U.S. revenue authorities to help each other in the assistance and collection of taxes.
However, that does not apply to penalties outside of the tax system, and it also does not apply to citizens. For any dual citizen who might be discovered and assessed U.S. tax liability, the treaty does not allow assistance and collection in relation to that person because they are a Canadian citizen. If they were only a U.S. citizen, then it's possible that the collection assistance provisions could apply. However, there are other considerations that have to be weighed before that rule kicks in. It has to be in relation to the basic tax, or tax related, and only after the final tax liability has been determined.