There are scholars who are going to be testifying at this committee who indicate that FATCA is “inconsistent” with the terms of the existing tax treaty we have between Canada and the United States because it “provides for appropriate changes to the treaty”. They say the intergovernmental agreement explicitly implements the FATCA agreement, but “superficially”. It only appears to meet the standard, and that the IGA introduces “an unprecedented asymmetry in the treaty”. They recommend that the government explain why normal treaty amendment processes haven't been followed and we have this asymmetry introduced into Canada.
Would you have any comments on that analysis, that lack of symmetry?