Mr. Chair, through you, I just have a couple of comments and clarification questions for our witnesses.
Mr. Ernewein, you did indicate that there is a narrower level of information that is being contemplated under the IGA than what would have been contemplated under FATCA, or what would be in place under FATCA if we did not have an IGA.
I think this is one of the questions we seem to be arguing: the IGA or not an IGA. We have an IGA, but we could be in a situation where we don't have an IGA, but FATCA is going to apply to Canadians and to banks even if we don't have an IGA. It's going to happen anyway.
There were two factors that you talked about. One was a narrower level of information. I also understand that the due diligence procedures that you just commented about with respect to the electronic checking of low-value accounts, those actually less than $1 million, require basically a much higher level of information and less scrutiny than most other countries have received.
I think it's important because there are a number of these amendments that we're going to be looking at. I think a lot of them are going to try to accomplish the same thing, but I think the answer to most of them is the same. Under this case and this amendment that's being proposed, and which Mr. Rankin talked about, if not dangerously, we would be in non-compliance with the IGA if we started restricting their U.S. citizens, and they talk about permanent residents as well.
The question is, if we invalidate the IGA, what situation will we be in? The U.S. may say, “Fine. No problem. You're too restrictive, and that's not what we're going to have any more. We're going to come back with FATCA, and we're going to negotiate one-on-one deals with your banks”, which is what they would have done.
There would not only be a 30% withholding on the banks, but also on transfers of dollars to individuals in Canada as well. I could imagine the sputtering that would be going on in our offices if 30% withholding was based on transfers coming to individuals.
In that context we have to be very cautious about looking at any amendments to this. I look at this amendment as being one that would potentially invalidate the IGA in the mind of the U.S.
Can you give that context for us right here?