Particularly with the offshore tax informant program, the provisions for the protection of informants is not clear enough. I know this from personal experience, having talked to several people who had information they wanted to come forward with. As you know, some of the tax cheats using tax havens are connected to criminal organizations, so these people have a very real fear for their lives—I have talked to them—yet they feel they should do the morally correct thing and come forward with this information.
I don't think there is sufficient protection. As a previous witness mentioned, there may be provisions that would apply if it's a criminal case, but in a civil case that is not there. There are some significant improvements that are still needed.
What's also not clear is what the staffing capacity is going to be to implement this program. In the United States they have 40 staff in the IRS Whistleblower Office. We know Canada is a smaller country, so maybe we don't need that many people, but I've heard that government was thinking of only having one or two staff. I don't know if that would be adequate to roll this program out in a good way.