Hoang Mai on Questions Passed as Orders for Returns

With regard to the Canada Revenue Agency’s (CRA) responses to the provisions of the Internal Revenue Service (IRS) regarding the Report of Foreign Bank and Financial Accounts (FBAR): (a) according to the government’s analysis, do the IRS provisions comply with the provisions of the Convention Between Canada and the United States of America With Respect to Taxes on Income and on Capital and its amending Protocol (2007); (b) are there Canadian exemptions to FBAR; (c) has Canada negotiated the FBAR provisions with United States Treasury Officials or the IRS, (i) at what time was the government made aware of these provisions, (ii) how long did it take for Canada to respond to the changes made by the IRS and the United States Treasury; (d) how will the government ensure that the CRA does not act on behalf of the IRS to collect revenues and penalties; (e) has Canada informed dual citizens about their tax obligations resulting from FBAR; (f) what was the number of exchanges of information between Canada and the United States of America this year and during the past ten years regarding FBAR, (i) has the CRA set internal deadlines to be able to respond to exchange of information requests in a timely manner, (ii) will Canada work to improve bilateral cooperation on this issue, (iii) has there been an increase of exchange of information requests at the CRA due to FBAR; (g) will the government lose revenue as a result of the implementation of FBAR; (h) what are the cost implications emanating from FBAR (i) for the government, (ii) for the CRA, (iii) for Canadian banks, (iv) who will absorb these costs, (v) are there other types of non-financial costs such as efficiency or fairness reductions; (i) how many complaints has the CRA received regarding FBAR or related vexatious inquiries by the IRS, (i) what are the main complaints, (ii) what has the CRA done concerning these complaints, (iii) what department at the CRA is in charge of dealing with complaints of this nature, (iv) will the CRA cut Full-Time Equivalents from that department or reduce its funding, (v) has the office of the Taxpayers’ Ombudsman looked into the matter; (j) will FBAR prevent double taxation of pre-migration gain; (k) has there been an increase in arbitration cases due to active procedures by the IRS, (i) what departments are most affected, (ii) has the CRA cut Full-Time Equivalents from each of these affected departments or reduced their funding; (l) will FBAR affect different saving vehicles such as, but not limited to, (i) Registered Retirement Savings Plans, (ii) Registered Education Savings Plans, (iii) Registered Disability Savings Plans, (iv) Tax-Free Savings Accounts; and (m) how many Canadian-American dual citizens are affected by FBAR and does Canada have contact information for the dual citizens affected by FBAR?