Mr. Speaker, Canada is one of 113 jurisdictions that have signed a model 1 intergovernmental agreement, IGA, with the United States of America, U.S., with respect to the Foreign Account Tax Compliance Act, FATCA.
Under the IGA, the CRA acts as a conduit to facilitate the transmission of financial account information of “U.S. persons” from Canadian financial institutions, FIs, to the U.S. Internal Revenue Service, IRS. Information regarding “U.S. persons” can be found under article 1(ee) of the IGA: https://www.fin.gc.ca/treaties-conventions/pdf/FATCA-eng.pdf.
In response to part (a), the approximate numbers of records sent to the IRS under the IGA for the years in question are as follows: 600,000 in 2017, for 2016 tax year; 700,000 in 2018, for 2017 tax year; 900,000 in 2019, for 2018 tax year.
In response to part (b), with respect to the increase in records over time, the following factors are of particular relevance.
In addition to the IGA, the common reporting standard, CRS, was implemented in July 2017. As a result of this development and FIs’ desire to align their compliance requirements for these two regimes, more U.S. reportable accounts were identified. Also, when the CRS came into force, legislation was amended to require self-certification on all new accounts for both the IGA and CRS, which also resulted in an increase in records.
Furthermore, as the exchanges under the IGA operate by records and not by account holder, more than one record can exist for any person or entity. As time goes on, new accounts are opened and there are changes to account information, such as updates to an address or to produce a tax identification number, which creates additional records, even though they relate to a single account and taxpayer.